ML20100H212

Forwards Response to NRC 841227 Order Re Certification of Compliance w/10CFR50.49 (Generic Ltr 84-24).Util Previously Submitted Ltrs Re Environ Qualification of safety-related Equipment in Response to IE Bulletin 79-01B

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 611 Ryan Plaza Drive, Suite 1000 M27E 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 3 PSC has previously submitted many letters concerning environmental

,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. S ma.a.

2. Summarized review on seismic qualifications of Class I equipment and environmental qualifications of safe shutdown (Of p equipment, ytd,p.bp\

3 3. Established corrective action for unqualified Class I N  ;

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' PSC Letter dated June 12, 1979 Fuller to Seyfrit (P-79124)

1. Determined :the matter of environmental. qualification closed l 4 . with Amendment:18 to the Facility Operating License DPR-34.

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-2. Listed Erelevant correspondence between PSC and the NRC 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' d March 18, 1980 Swart to Seyfrit (P-80051)

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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).-

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3. Discussed areas not applicable to a High Temperature Gas-Cooled Reactor-(HTGR), details of DBA#1. (Attachment "C" to including P-80051) radiological

-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.

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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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2. . Ccmnitment to completion of enviraranental testing of generic items. l

3. . 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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f. 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

} ~-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

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

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to'a humidity level similar to actual event conditions.

3. ' Chanical Spray

Chemical sprays are not utilized at FSV.

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f 4. 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.

j 5. 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.

$ Aging 6.. ~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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j. 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"

]' -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-

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Lreplaced. All units were subsequently tested and qualified.-- As part of this auditfor records were placed in a'more auditable' form.

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$ There- are. presently several methods -utilized to identify _ safety . related

.equipnent and their respective qualification requirements.

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! 1.- -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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3. Electrical schematic diagrams highlight the exact circuitry that nust i . function in order to provide a safe. shutdown.

-4. %e Safety Related Canponent List . (SR-4-2 ) _ identifies . specific equipnent and . instrunents that are . safety related. SR-6-2 also.

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definest the environmental; qualification requirements 'for~ safety

, related instruments and equipment.

5. - Design Directives 1are__used to provide guidance in detercining the enviru._ Ral' qualification requirements. of new equipment.

1 c, %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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l 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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[ [Olass I 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.

I '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.

). 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 w that has an effect on a Class I function is . itself 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 ::ntss are qualified accordingly.

1 o PSC~ iletter Warenbourg to Johnson dated. February 28, 1985 (P-85065) identifies

{ 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.

.~ -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).

l h 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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'IE Information Notice 83-45: 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

- rwima,; we feel that moisture: intrusion into safety. related equipnent in

!~^,- high : . : htanidity, high temperature' areas is not ; a problem,'. .we .are

[ iinvestigating the possibility of inproving maintenance procedures to ensure f'

< protection'a 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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i ' IE Information. Notice. 84-78: The concerns'of underrated terminal -blocks in  ;

[ Limitorque operators.are similiar to those raised in Information Notice 83- )

[ 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.

. 'Ihis s wtan has taken into consideration and applied, as applicable, areas of ,

i 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.

[- 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 All, of;'our'equignent which PSC has determined -is required.to be qualified has I. been qualified by;our EQ z program.

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-All of- the specific action items identified in Generic Intter184-24 have been

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address'ed.-

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Based! on our positions: stated 'herein, ;we feel that we are in ffull? 'ompliance

, 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)

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4.- Firewater via Emergency Feedwater -(2. Fire Pumps)*** OPL

.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)*** OPL

. Condensate Line

, Number of Circulators Per~Icop 2 Sources'of Motive Power to- Equignent ' Incation Circulators

1. Cold Reheat Steam main turbine steam .. IB2 p- 2. Auxiliary Boiler Steam' (2 Auxiliary . TB2 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)*** OPL

, . 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' 4

NUCLEAR REGULATORY COMISSION

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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

l .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 )

COUNTY OF h Subscribed:.and swornL to before me,(a Notary Public.on this1 2 F A day of MA , 1985.

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.Kotary Public xc, r. 1 0 4 % '

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- My commission expires- (/ufM /1 ,1982 -

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