ML20101C601

Applicant Exhibit A-20,consisting of Re Environ Qualification at Facility

ML20101C601
Person / Time
Site:	Farley
Issue date:	02/19/1992
From:	Clayton F ALABAMA POWER CO.
To:
References
CIVP-A-020, CIVP-A-20, NUDOCS 9206090288
Download: ML20101C601 (52)

Text

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February 29, 1984-Docket Nos. 50-348 4

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e oooen Director, Nuclear Reactor Regulation APP,'13 E $

U. S. Nuclear Regulatory Commission h

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EECY41RC Attention:

Mr. S. A. Varga

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Joseph M. Farley Nuclear Plant - Units 1 and 2 Environmental Qualification Gentlemen:

On February 4,1983, Alabama. Power Company ( APCo) received the Safety Evaluation Reports (SERs) regarding the environmental qualification of

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safety-related electrical equipment at Farley Nuclear Plant (FNP), Units 1 and 2 defined by _IEB 79-01B and NUREG-0588 respectively.- The SERs each contained a Technical Evaluation Report (TER) which noted deficiencies

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corcerning the documentation of qualification-for.several safety-related items at FNP. Gn January 11, 1984, a meeting was held with members of the NRL Staff to discuss APCo's responses that resolved each identified deficiency. In addition to the TER items, APCo discussed with the NRC Staff clarifications related to (1) specific NRC Staff questions identified at the meeting concerning generic environmental qualification' issues and (2) the scope, environmental qualification criteria, and schedule provisions of 10CFR50.49(b)(3). This letter documents the discussions held-at _the January 11, 1984 meeting.

! of this letter summarizes each identified TER deficiency' as discussed with the staff. The only outstanding action item is a review of the qualification reprt for the Target Rock solenoid valves used on the reactor head vent system. The qualification report is currently under development by Westinghouse with a scheduled completion in 1984. APCo has reviewed the draft qualification report and determined that these-solenoids are qualified for use in the FNP containment.~ APCo will review the final report when issued to ensure the qualification is maintained. These solenoid valves, however, are not within the scope of IEB 79-01B and NUREG-0588 since, as stated in APCo letters dated June 23, 1982 and May 20, 1983, such equipment is addressed by the 1MI Action Plan and is not essential to achieve a safe shutdown condition- ~ The schedule for the full environmental qualification of the solenoto n L'es, therefore, does not

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impair the safe shutdown capability of FNP.

9206090288 920219 PDR ADOCK 05000348:

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0057023 Mr. '. A. Yarga February 29, 1984

• j U. J. Nuclear Regulatory Commission Page 2 O

In the January ll,1984 meeting, the NRC Staff requested that this letter include additional clarifications regarding specific NRC Staff the meeting on generic environmental comments identified during's responses,to these specific coments are qualification issues. APCo included as Attachment 2.

Documentation of the discussion related to the scope, environmental on.alification criteria, and schedule provisions of 10CFR50.49(b)(3),

amicable to the FNP, ws provided in Attachment 3 to the.'4Pto letter dated F. wuary 22, 1984 addressing R.G. 1.97 equipment within the scope of lutFR50.49(b)( 3).

As stated in letters dated March 14, 1983 and May 20 1983, it is the judgement of Alabama Power Company that ali equipment required to achieve a safe shutdor.n conditio.. at FNP is environmentally qualified and Justifications for Continued Operation (JCO) are not necessary.

As discussed in th January 11, 1984 meeting, it is requested that supplemental SERs be issued to indicate that the APCo Environmental Qualification Program meets the requirements of 10CFR50.49(b)(1) and (b)(2) and that all deficiencies noted in the SERs dated February 4,1983 are resolved.

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It is noted that information provided in Supplements 1, 2, 3 and 4 to O include data which is proprietary to Westinghouse. Enclosed as to this letter is a signed affidavit from Westinghouse requesting that this information be withheld from public disuosure. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the Commission's regulations. Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld fram public disclosure in accordance with 10CFR Section 2.790 of the Comission s regulations. Correspondence with respect to the proprietary aspects of this application for withholding or the supporting Westinghouse affidavit should be addressed to R.. A. Wiesemann, Manager, Regulatory and Legislature Aff airs, Westinghouse Electric Corporation, P.O. Box 353 Pittsburgh, Pennsylvania 15230.

E If there are any questions, please adsiu.

Very truly yours,

~~--'k, F.T. Q C I n j-4 ?:

Clayton, Jr.

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0057024 Mr. $. A, Varga Febmay 29. HB4 U. $. Nuclear Regulatory Commission Page 3

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Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradf ord Mr. T. Conlon

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Mr. W. G. Hairston, 111 0057G25 Mr. J. W. McGoman Mr. C. D. Nesbitt

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Mr. R. G. Berryhill Mr. D. E. Mansfield h'-

Mr. J. A. Ripple Mr. W. G. Were Mr. L. B. Long Mr. B. J. George Mr. J. R. Crane Mr. K. C. Gandhi Reference Listing

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• IER ERC DiflCithCit PROPO*.ED 50LUIlon Cent litM ho.

FUhCI!ON/D[$CalP!!0E CAILLOAV-

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o tw 1.3 Containment Isolation 11.4.

Adequate Stallarity Bet.een [ quip-Limitorque letter dated so tev335uA.B.C) meat and Test Spectace Established Oc tober 13, 1960 C

(Nv3232A,8.C)

Aglag Degradottea [ valuated documented siellarity.

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Adequately Liettorque Test lieport (Mov35301 Quantited Lt te or Replacement

" Nuclear Quellitcattoa*

(Mov 35284.8.C.D)

Schedule Established (If acquired)

Section 3.1 establishes imV3535A.8) qualtitcattoa la escess of (M0V W 2A.8) 40 years.

(M018112)

(Mod 3t.60)

(Huv33taal (Mov3046)

(293441 A.B.C.DI (Mov313tl 2

Contalancat Isolation

!!!.a Laempt moae Required.

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II. SottmotD WALvis uwli Ita sac Onf IIIM NO.

fumCI!ON/DE*iNIPTIOu CATEGOAt DtFICIlmCits PROPOV D 50LuT10m p2 4.8.9 Actuate Air Operated Valve II.a Qualthed Life or Replacciacat A qualified life of 8 years o

for Isolation Sche &te [stablished (If Required) has been established for ASCO Criteria Segarding Submergence solenold valves laside coa-p Satisfled talament. These solenoids are g,9 located above the flood level o

or will perfons their latended O

function prior to becentag si.bmerged and will not mislead f

the operators 5.10.13 Actuate Air Operated V:

1.h Pendtag Modificattoa These valves were replaced 14.15 for Isolatsoa with quallfled ASCO kP or 206 series solenoid valves '

that beve a qualtfled life of 8 years taside costalament had 18 years outside contalament.

7 Reactor Head tect Systes I.!*

Pending Mo46ficatloa APCS will revlem tw Target Rock solenoid valve test report when issued by Westinghouse for applicability to fmP. The test report is currently scheduled to be I

issued durtag the second quarter of 1984.

6.11.12 Actuate Air operated talve II.c Qualtfled tife or Replacement A qualified life of 18 years for Isolation Scheele Established lif Required) has been established for ASCO solemold valves outside coa-tatament, and a qualified life of 8 years has been established for ALCO solenoid valves lastde coatalament, w

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flihCII0a/DESCalPfl04 CAltGORY OfflCIEWCits Pit 0P05ED ' 50LUI10el n

Q 17 Wydrogen Concentration Il a Adequate Siellarity between [ quip-American Air Filter letter 6

ReActica sad Contalement meat and lest Specha EstAlished dated krch 22,19ti3 docunea-W Coolimg ted Joy hauf acturiog Ceapany*s o

Report X-604 dated April 6 o

1977 is applicale to the f aa actors for the fue ustt I contalament coolers. The motor data for actors used la the Post-LOCA Hydrogen Control systee indicates that these motors are generically the same as the motors tested in Joy's Test Report I-604, and hence are fully quallited for use inside the FNP Costalement, G

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fuuCIl0N/Df50RIPiluN CAlts.ORY DlflCitMCl[5 PROPOSED 50LUTIOs o

18, 19 Acactor Trip I.b Aging Degradation Concere See Supplement 1 6

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schedule [stahltshed (1i Required) o Criteria negarding spray o

Criteria negardlag Functicaal Testing Criteria Begarding lastrument Accuracy O

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. Radiation Moottor I.b Adeepsate Stellarity Bet.een Victoreen Qualification Test Equiparat and Test Specineas Report No. 950.301 dated Established Jusie 19, 1981, fully supports W

the qualification of the O

detector (Model 877-1) and the O

cable (Madel 878-1) lastalled at FmP. Dupilcation of the sealing procedure followed la the Victoreen Test Repcrt No. 950.301 esas laplemented on the detectors lastalled at FHP and, therefore, metalataed qualification.

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FUNCil0N M 50RIPilow CAlttARY DiflCllhCl[5 PROPOSED 50tuTION M

21 Post Jkcident Maaltor 1.b Agiaq Degradattaa Concera See Lpplement 2 Q

26.45 tevel ladicatloa Quellfled Life or keplacement p

Schedule Estahlished (If acquired) g Crateria Regardlag Submergrace o

Criter?4 Regardlag lastrument o

Accuracy 22 ke4ctor Trip 1.b aglag Degrad4 tion Concera See Supplement 3 Qualified Life or Replacement Schedule (stablished ilf Required)

Criteria Aegarding Radiation Criteria Regardlag Test Sequence l

23 que f eed Pump Trip II.b Adequ.te Steilarity Between See Supplement 4 25

. Post Accident Level mattor Equipeest and Test Spec 8 mens istab)ished Aging Degredatica Concera Criteria Aegarding Test failure or Severe Anomalies (If Any) 9

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WII. PRLi$uki AND LEYLL TRAsimitlini (Cont *C) unil Ita uxC ChL

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fuktituu M 5CalPilos CAltLear DItIClimCiti PROP 04 D 50Lui!OW

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24 Level ladicattoa 1.b Docenented Evidence of Qualification inese level transaltters were Adequate lastalled as a result of a comes taent to mostter the marrow range containment sump to satisfy NUREG 05tse.

The actual test was completed durias the foierth quarter of 1982 and the test results were issued from Wyle Laboratories en December 8. 1982, as hEQ Test Report 45700-1. Based ca the results of this test report, tne Gems-Delavel level monitor in the costalement leakage collectica sump is environmen-tally qualtfled for use la the FMP costalement.

27 feekter Control I.b Aging Degradatica Coacern See supplement 3 Qual 1iled L6ie or Reptacement Schedule Established (if acquired)

Criteria Regarding Radiation Criteria Regarding lastrument Accuracy test Duration Margla (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and function Time)

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VIII.. LIMli iWIICMS Ita haC unt!

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f uuCilum/Df 50tiritum CAltLoaf Du lcituCits Pit 0 POSED 50 tut 10m Cui p

23, 32 valve Posittoa Indication II.c Qualified Life or Reg,lacement A quellfled life of 8 years Scheasle istablished (if Required) has been established for M

hAMCO EA-180 llelt switches g

f aside costalament.

p 29, 30 dalve Posittaa ladicattoa 1.b Pending Modification These liest switches have O

31, 46 been replaced with quallfled O

MAMCO EA-180 limit switches.

l The udWC0 EA 180 limit switches have a quellfled life of i

8 years tasids costalament and 18 years outside contalement, i

33 valve Position Indicattoa II.a Qualified Life or Replacement A quellfied life of 8 years l

l Schedule Established (If Required) has bess established for l

Criteria Segarding Submergeace NAMCS EA-180 limit switches

$atisfied laside containment. These Italt switches will act be subject to submergence or

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will'perfore their latended function prior to becentag submerged and any circuit shorts that could occur will not mislead the operator.

(Reference APCo subatttal response to TER dated March

14. 1983.)

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39. 40 Electrical lastrumentation 14 nocumentattoa not Available The IbP cables have been 4.

fully quellfled by Sottoa lasulated Were and Cable Company's fest Report 73E062, dated September 7 - 1983 and -

g their clarlfication letter g

dated August 2f.1981. The g

test report was submitted to the hAC la the May 20. 1983 O

response to 10CFA50,49. The-O test conditions envelop the O

FMP service requirements.

42, 43 Electrical Power and Control 11.4 Adequate $1milarity 8etween la a letter dated June 22. 1981, 44 Equipment and Test Specimen the Okoette Company has certi-Established fled that all power and control cables supplied for Joseph M. Farley nuclear Plant '

Unit 2 are quallited by Test Aeport N-1, dated July 2 1978 As documented by Bechtel letter -

AP-6155 dated September 2.1981, the cables for Joseph M. Farley -

Nuclear Plant Unit 1 were procured i

1 to the same spectfications cs the unit 2 cables and are identical la construction to the Unit 2 cables. Therefore. all p itfied power and control cables are fully qualified by Test Report M-1 dated July 3.1918.

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1.3 Contalanet Isolatson 31.4.

Adequate stat tarity Betmeca Equip-Stellarity is documented by LO INVl%04.8.C) meet and Test Specimen Established Limitorque la letter dated O

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Ag6ng Degradation Evaluated October 13. 1980.

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Ateentely Limitorque Test Aeport (80VE30)

Qualifled Life or Replacement

• anaclear Qualifications

• IMtJW 331oul Scheme Established (if acquiredi Sectica 3.1 established (se0vis112) quellfication la escess IMcWla124,5) o' 30 years.

(M0W3no) 2 Castalament Isolation 111.4 faempt Nome Required.

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4 Acteate Air Operated Valve

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- Qualified Life or Replacement A quellided life of 8 years

• 7 for Isolation Schedule Established !!f Recpired) has been established for CD

..riteria Aegardlag Submergence ASCO solemold valves lastde N

Satisfied costalament. These solenoids are located above the flood Lt3 levei inside containment or o

will perform their tatended o

function prior to hecentag submerged and will act mislead the operator.

6 Reactoc Head went System I#.

Pendnag Modification APCS will review the Target l

Sock solenoid valve test I

report when issued by idestinghouse for applicability to FMP. This test report is i

currently scheduled to be issued by idestinghause ertag j

the second quarter or 1964.

7.9 Acteate Air Opertsed Valve 1.b.

Pendlag Modificatica These valves vers replaced for Isolation with qualifted ASCO kP series solemold valves that have a quellfled life of 8 years faside containment

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and a qualtfled life of 18

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years outside containeest.

J 5.8.10 l Actuate Air Operated 1)alse j

't.c Qualifica Life or seplacement A500 NP series solenoid valves for 1501sttee Schehle Established lif Requiredi have a qualtfled life of 18 years outside containment.

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tutC N IWO liEst uc.

FUNCi!0W/DE5CalP!10W cal [00mv OtflCitucif5 PROP 05ED SOLUTIDs c

N 12 Hydrogen Concentration II a Adeiguate similarity Betmeca Equip-Assertraa Air Filter letter 10 keductica sad Coatalament meat and Test specimen Established date<! March 22, 1983 C

Cooltag

1. doc 4 Aeated Joy mauf acturtag O

Cepany's Report I-604 dated P -il 6. 1917 is appilcable t i th t faa motors for the faiP ' Alt I costelament coolers.

T>e fue unit 2 contalement ruoters are identical to those lastalled la Dalt I and were supplied by Joy h aufactarlag. Therefore, tt:e salts ta Unit 2 are fully quellfled. The motor data for actors us2d la the Post-LOCA HyJrogen Control systee ladicates that these aclars are generically the same 45 the motors tested la Joy's T. st Report I-604, ased hence 4.e fully qualtfled for use inside the FhP costalament, v

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ItartaAIURC MLA$UitikG DLVICi$

unti 11R NRC Tes) liLM h0.

FumCil0N/ DESCRIPTION CAltLuaY Dif!CILMCl[5 PROP 051D 50Lul104

13. 14 Reactor 1rtp I.b Aging Degradation Cowera See Supplement 1 y

Qualified Iife or Replacement g3 Schedule Established (if aequired)

Criteria Segarding Spray Criterta Segardlag Tsactional O

Testtag O

Criterte aegarding lastrument Accuracy m9 9

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W! RADIA!!OW DtlLCIORS us!!

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FUNCIldW/Dt SCRIPl!ON CAltbONY DeflCituCit5 PROPOSED SOLUTION mm____,..

L' Radiattaa m atter 1.b -

Adequate Similarity netween Victoreen Quantfication Test Equipment and Test $pecsacas Report No. 950.301 dated tf3

[stablished June 19.1981, fully supports M

the qualificatica of the l

C detector (Model 877.1) and the cable (Model 878.1) Installed d

at FhP. Duplication of the sealing i

O procedure followed in the Victoreen l

C Test Report No. 950.301 eas laplemented oc the detectors lastalled at FWP and, therefore, malatainlag p lifscation.

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VII. Pklituki AND LEVIL 1RAWAIIIt".5 Unli

~ Tia Nkt Two 11EM E0.

FUNCI!ON/DESCRIPil0N CAIELost DifICithCIf 5 PROPOSID SOLU! ION 16 Post-Accident maitors IV Documentation hot L de Available Westinghouse proprietary 17 acactor 1rtp document WCAP-9685 is the e

21 Pressurtier Level. Fece ater qualificatica document for Control. Level ladication Barton Transmitter (Lot 21.

n 22 feca.ater Coat-ol see kpplement 2 for additional c3 information.

p 18 Main feed Pump Trip II.b Adequate ilailarity Betweer.

See %pplement 4 20 Post-Accident Level Naitor Equipment and Test Specimens Aging Degradattoa Evaluated

. Criteria Segardlag Test failure w Severe Anomalies (if Anyl 19 tewel ladication 1.b Pending Notfication -

Wyle Laboratories Test Aeport festiog mot Completed 46700-1 dated December 8. 1982 documents qualitication of the GMS-Delaval level i

scattors..

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fuuCilus/DESCRIFilon cal 1GGRf DtFICl[NCILS PROPOSED 50Lui!0W ILR WC Imo

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23 valse Position Indication II.c Qualified Life or Replacement NAMCO EA-180 limit switches Schedule Established lif Required) have a qualiffsd life of 8 years inside contalament and 18 years outside containment.

24 Valve Position Indicatloa i f..d-Ajing Degradation Evaluated AAMCO EA-180 limit switches g

Adequately located outside costalament g

Criteria Regardlag Submergence have a qualified life of 18 g

Sa tisfied years. These limit switches O

are located above the flood C

level or have matertight fittlags lastalled on them that have been qualified by test la accor(Jace with submergence requirements of waCG-0588, Section 2.215),

Category II. (Reference APC0 submitted response to TER dated March 14,1983) 26 Walve Positien ladicatloa 11.4 f)ualified Life or Replacement hAMCD EA-180 Itait switches Schedule Est4blished lif Required) located loside containment have Criteria Regarding hbaergence a quellfled life of 8 years.

54tisfied Ihese liatt switches are located above the flood level or reill perfore their intended function prior to becoming submerged and any

' circutt shorts that could occur fw(Referen'eAPCosubmittal ill not mislead the operator.

rs=oonse to if R dated March 14 I iv3)

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XI. CABLE UNIT 118

~fuuCIION/DESCalPTION CATELORY DiflCl[NCIES PROPOSED SOLUTION pgC IWO '

- !!EM NO.

34,35,36,37 Electrical Instrumentation IV Documentation not available Boston lasulated Wire'and Cable company's Test Seport 73E062, submitted to the NAC.

O la the May 2G, 1963 response.

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' fully quellfles the referenced O

cable.

6 to 38.39,40,41 Electrical Power and Control

!!.4 Adequate Stanlarity Between-Otonite Cable Company letter o'

Equipment and Test spectaea dated Jute 21, 1983 certified o

Established all cable supplied to TNP is quellfled by their test report N-1, dated July 3,1918.

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0057G51 Supplement 1-Proposed Solution for the Rosemount RTD's Unit 1 TER Items 18 and 19 Unit 2 TER Items 13 and 14 "ALL INFORMATION ON THIS PAGE REDACTED AS PROPRIETARY PER LICENSING BOARD ORDER"

0057652 Supplement 2 Proposeo Solution for the Barton tot 1 and 2 Transmitters Unit 1 TER Item Nos. 21, 26 and 45 (Lot 1)

Unit 2 TER Item Nos. 16, 17, 21 and 22 (Lot 2) 4 "ALL INFORMATION ON THIS PAGE REDACTED AS PROPRIETARY PER LICENSING BOARD ORDER"

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Supplement 2 0057653 Proposed Solution for the Barton Lot 1 and 2 Transmitters Unit 1 TER ltem Nos. 21, 26 and 45 (Lot 1)

Unit 2 TER Item Nos. 16,17 21 and 22 (Lot 2)

Page 2 t

"ALL INFORMATION ON THIS PAGE REDACTED -AS PROPRIETARY PER LICENSING BOARD ORDER"

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supplement-3 00576'54 Proposed Solution for the Foxboro Models Ell (MCA) and E13DM Transmitters

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Unit 1 TER ltem No. 22 and 27-

"ALL INFORMATION ON THIS PAGE REDACTED AS PROPRIETARY PER LICENSING BOARD ORDER"-

Supplement 3 0057655 Proposed Solution for the Foxboro Models E11 (MCA) and E130M Transmitters Unit 1 TER Item No. 22, 27 Page 2 "ALL INFORMATION ON THIS PAGE REDACTED AS PROPRIETARY PER LICENSING BOARD ORDER"

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a Supplement 4 0057656

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Proposed Solution for the Gems DeLaval Transmitters (Models LS36497 and XM36495)

Unit 1 TER ltem Nos. 23 and 25 Unit 2 TER Item Nos.18 and 20 "ALL INFORMATION ON THIS PAGE REDACTED AS PROPRIETARY PER LICENSING BOARD ORDER"

0057057 (O

Resolutions to Specific NRC Staff Comments V

Idantified at the January ll,1984 Meeting 1.

NRC Connent Provide criteria and methodology utilized to develop the Equipment Master List for Farley Nuclear Plant Units 1 and 2.

APCo Response The criteria and methodology utilized to develop the Equipment Master List for Farley Nuclear Plant Units 1 and 2 are as follows:

1) Electrical systems and components in a harsh environment required to perform a safety-related function are included in the Master List.

2) The control circuitry of components identified in Item 1) above was reviewed for connections (interlocks) to other safety-related and nonsafety-related components. If spurious or inadvertent operation due to environmentally induced f ailures of the connected components in the harsh environment could adversely affect the completion of a safety function, the connected (interlocks) safety-related or f

nonsafety-related components were included in the Equipment Master

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List.

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3) The instrumentation circuitry of components identified in Item 1) above was reviewed for ronnection to other safety-related and nonsafeny-related compvnents.

If spurious or inadvertent operation due to environmentally induced f ailures of the connected components in the harsh environment could cause erroneous indication of the status of safety-related components, the connected safety-related or nonsafety-related components were included in the Equipment Master List.

4) The power circuitry of components identified in Item 1) above, inside the harsh environment was reviewed.

If environmentally induced failures could result in a loss of power to components required to complete a saftty-related function, the safety-related or nonsafety-related power circuitry components were included in the Equipment Master List. There are no connected safety /related/nonsafety-related power circuits in the harsh environment.

The Equipment Master L1st developed from this review criteria and methodology identifies safety-related equipment that is relied upon to remain functional during and following design basis events and nonsafety-related equipment whose environmentally caused failure could unacceptably impair the intended function of safety-related equipment. In

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the opinion of Alabama Power Company, the equipment identified in the Equipment Master List complies with paragraphs (b)(1) and (b)(2) of c( )

10CFR50.49.

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_ _ _ - _ = _ - _ _ -

l Resolutions to Specific NRC Staff Comments 0057658 Identified at the January 11, 1984 Meeting O

Page 2

'V 2.

WRC Comment Provide a description of the Environmental Qualification Administrative '

Program (EQAP) implemented at Farley Nuclear Plant.

APCo Response APCo has developed an E0AP to ensure that currently qualified equipment within the scope of 10CFR50.49 will be maintained qualified throughout the-life of the plant.

It is the position of APCo that this program complies with 10CFR50.49, DOR Guidelines and NUREG-0588 as described herein.

i Design Control The E0AP requires that each design change will-identify equipment that must be environmentally qualified and,- for equipment models not previously installed at FNP, will reference the test report applicable to the equip-The designer is responsible to ensure that the specified configura-ment.

tion is qualified and satisfies the Farley-specific harsh environment. A -

list of vendor test _ reports- (Acceptable Test Report List)' previously -

reviewed and found acceptable is maintained as a controlled document by Farley Document Control.

Procurement Control The EQAP requires that Material Requisitions identify equipment- -

requiring qualification and the test report associated with the specified :

i equipment as indicated _by the Equipment Master List and Acceptable Test Report List.

The program requires that engineered requisitions be prepared 1

by the designers for equipment specified in a design change but not included on the Acceptal,ie Test Report List. The Equipment Master List, a controlled document maintained by Farley Document Control, identifies, by plant I.D.-

numbers all equipment.to be qualified..The EQAP provides that subcompon-ents not. assigned a plant'I.D. number satisfy the applicable environmental requirements of the equipment having a plant I.D. number of which the subcomponent is a constituent part. The Acceptable Test Report list identifies all test reports that have been reviewed and found acceptable.

The vendor is required to submit a test report for equipment not previously.

installed at FNP or, for equipment previously installed at FNP, a certificate of conformance to a report identified on'the Material Requisition. All new test reports not identified on the Acceptable Test 1

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00576591 Resolutions to Specific NRC Staff Comments j,

Identified at the January 11, 1984 Meeting Page 3 Report List as-required to be reviewed and their acceptability l

documented before the--issuance of a purchase order.

4 j.

In accordance with. the ECAP, components used to maintain qualified equipment must be qualified to the applicable requirements-of the equip-ment being maintained. -Identical components-used'to maintain the ' _

qualification of equipment are to be qualified by exisiting test reports-which have been reviewed-to meet the requirements of the_ DOR guidelines t

or NUREG-0588..lf identical components cannot be obtained, the existi_ng equipment is required to be replaced with new components procured to meet provisions of test > reports-that have been ' reviewed and accepted by APCo to the requirements of 10CFR50.49. _ A component used for. the-4 i

maintenance of environmental qualification is 'not to-be' consi.dered' l

identical if its installation requires a design change _ or its environ-i mental-qualification test report has not been reviewed and: accepted by :

l' APCo.

t i

Storeroom Control i

The EQAP_ assures that the storeroom provides qualified equipment,-

which is identified by plant I.D. number on-the Equipment Ma_ ster List.

for installation into the plant by completing a_ Material-Issuance Form.

Inventory level is maintained by the :use of. the FNP. Inventory = Record System. Material ~ is. stored and handled in accordance with appropriate i

vendor's instructions and storettom practices. Proper segregation of environmentally qualified equipment from equipment that is.not~ qualified is employed using storage room bins and locator numbers. -

l Preventive Maintenance The EQAP identifies components; requiring maintenance and their maintenance _ f requency. The EQAP provides scheduled. maintenance of-limited and indeterminate _ life components /subcomponentsLand materials and will ~ schedule the normal maintenance of 40-year-life equipment..

i limited life equipment has.a qualified life ofllessLthan 40 years.:

Indeterminate life equipment has not been subjected to: thermal age-testing and does not include material and subcomponents-.that are known -

to be susceptible :to significant-age. degradation. Maintenance F

activities include selection of the component for:which-surveillance is performed. Component examination is required to be performed by-:

maintenance personnel in accordance with'the Environmenta11Qua11fication.

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Resolutions to Specific NRC Staff Comments 0057060 A

Identified at the January 11, 1984 Meeting O

Page 4 Surveillance program during maintenance activities. The program requires that the results of the component examination be assessed for aging in accordance with the Environmental Qualification Surveillance program described below. Failure to replace corrponents on schedule requires justification for interim operation.

Environmental Qualification Surveillance The E0Ap requires the 5ssessment of the effects of' in-service aging. This is a program of visual examination and document evaluation. The in-service surveillance procedures are keyed to the degradation mechanisms that have been identified and are capable of detection and interpretation by the FNP. Staff. The. methods of interpretation are not based on a statistical analysis of equipment failures or reliance on one indication, but rather a consideration and review of the total evidence of equipment operability based on in-house records, licensing documents-and vendor infomation. There at e three types of equipment addressed by the program: equipment with an indeterminate life, equipment with a limited life, and-equipment with a 40-year life.

Each of these categories is required to have an -

i incremental increase in surveillance requirements to compensate for the C) susceptibility to, or indeterminate-aspects of,-- aging degradation. The U

functional capability of 40-year life equipment, as with all equipment, is required to be subject to the normal cognitive responsibilites of plant personnel; no additional surveillance requirements will be specified by this program. The limited life equipment surveillance includes a documented examination of a sample of the subcomponents (specimen) replaced at the end of their life. The examination of the-specimen will be-documented-on the Spenmen Surveillance Checklist during the replacement of the subcomponents. The indeterminate life equipment surveillance includes an examination of a specimen'as well as completion of a documented evaluation of in-house records providing 4

insights to the condition of the equipment. The evaluation of in-house records are to be documented on the Document Summary Sheet. An evaluation of the Specimen Surveillance Checklist and the Document t

Summary Sheets will be performed and the necessary action taken (e.g.

procedure revisions, modification of-qualified life, no action necessary, etc.).

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Resolutions to Specific NRC Staff Comments Identified at the January 11, 1984 Meeting

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Page 5 0057661 V

Document Control-The EQAP ensures that documentation is forwarded to Document Control for permanent retention. The following is kept in the environ-mental qualification-central file or appropriately referenced to other 9

file locations:

test reports, evaluation documents, justifications for interim operation, certificates of conformance, maintenance requirements, Specimen Surveillance Checklists, Document Summary Sheets.

Work Authorizations, Production Change Notices (PCNs), Engineering Support (ES) Authorizations, Systems Performance Group Problem Reports, Problem Report Response Sheets and Material Issuance Forms. Also, Document Control maintains the Acceptable Test Report List and Equipment Master List as control documents for issuance to the appropriate organizations.

3.

NRC Comment Provide a discussion on the approach used to evaluate the infor-mation in IE Information Notices (IEN) regarding environmental-qualification problems and the mechanisms used by APCo to take any

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appropriate action. Specifically address IENs 81-29, 82-52 and 83-72.

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APCo Response Responses to IE Information Notices (IENs) and Circulars (IEC) are not requi ed to be submitted to the NRC. However, it is APCo policy that all notices and circulars are reviewed for applica-bility to FNP and formally documented in the FNP files for permanent retention. All required corrective action to any notis.

or circular applicable to FNP is determined prior to the response being written to ensure that all documented responses address each notice or circular.

Specifically, IENs 81-29, 82-52, and 83-72 have been. issued regarding adverse environmental qualification testing experience.

Described herein is the current status of APCo's review on these IENs.

IEN 81-29 IEN 81-29 identified ten items for which anomolous test results were documented during environmental qualification.

FNP has three items installed in various locations throughout the plant. These three items have been reviewed with corresponding corrective actions identified. These actions include a plant design change and the development of additional justification for each item.

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Resolutions to' Specific -NRC-Staff Comments

' 00 N-Identified at the January 11, 1984 Meeting l--

Page 6 i

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IEN 82-52 i

This information notice was provided--to inform the licensees of the' status and test results published in IEN 81-29. APCo has reviewed-IEW 82-52 and determined that no additional action is! required at this-time ~ and actions taken as a result of IEN.81-29 were not affected by this additional information.

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IEN B3-72 i

IEN 83-72 provided information of environmental qualification test;-

failures on twelve equipment items-APCo is presently evaluating those j

items applicable to FNP to_ determine if.any' corrective action is- '.

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required to provide compliance with-the notice. oThe conclusion-of this review will be formally documented in the FNP files for-permanent retention noting any required actions.

I l

4 NRC ' Coment -

l: O Address the current leakage of States Terminal. Blocks'and its effects on equipment within the scope of 10CFR50.49.

APC0 Response The environmental qualification. test report for States Company Terminal--

' Blocks, Wyle LaboratoriesLReport 44354.-1; provides the values of leakage currents. The States Terminal Blocks ~were-LOCA! tested with;an applied:

in voltage of 137.5 VDC which is-.the normal operation voltage' of' the-

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t terminal blocks.-- Instrumentation was attached to ~ the terminal blocks-at the conclusion of the LOCA test and leakage. current values were recorded... The yalues of leakage current,wert recorded from teminal-point-to-point and point-to-ground onithe States Terminal Block.- Also included were conductor-to-conductor and conductor-to-ground leakage'.

i current. - These values were recorded for multiple combinations with; an; l

applied-voltage of 137.5 VDC.-

The test leakage, current values are being used in the development

of' the revised FNP.' Est.rgency Operating Procedures. (EOPs) presently l

being prepared by Westinghouse /APCok 5.-

NRC Coment Confirm that design basis. events at FNP,. which could: result in a -

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potentially harsh environment including flooding outside containment :

-were addressed-inothe identification of safety-related electrical equipment at FNP required to be environmentally _ qualified.

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0057063 APCo Response The flooding and environmental (temperature and pressure parameters) effects resulting from the worst case High Energy Line Break (HELB) outside containment was considered in the-IEB 79-01B and NUREG-0588 analyses. The main steam valve room is the only area outside containment which is sub. ject to a HELB and contains components required to mitigate the accident.

The action taken to ensure equipment functions as intended is documented in the IEB 79-01B and NUREG-05BB submittals. The effects of flooding from HELB in areas outside containment other than the main steam valve room was analyzed as documented in FSAR Appendix-3K.

6.

NRC. Coment Identify the mechanism for verifying the accuracy of vendor's evaluation of the similarity of the test specimen to FNP installed equipment.

APCo Response

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APCo has vendor documents located in the FNP Central File which confirm

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or. certify similarity between environmentally tested equipment and the equipment installed in FNP. These vendors include Gems DeLaval, Joy.

Manufacturing, American Air Filter, Limitorque and Okonite Companies.

i As verification of the accuracy of vendor similarity evaluations, APCo is requesting each identified-vendor to provide a: discussion on the methodology used to reach the conclusior:s of their similarity evaluation. This discussion on methodology will be included in the FNP Central File. It is the judgement of APCo that the acceptance of-the vendor similarity evaluation information will provide reasonable confidence in the accuracy of vendor documents on similarity.

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4

Resolutions to Specific NRC Staff Comments O

Identified at the January 11, 1984 Meeting 005766.4 V

Page 8 7.

NRC Comment Ensure electrical equipment within the scope of environmental qualification is returned to its original installed configuration after maintenance is performed.

APCo Response As stated in the Environmental Qualification Administrative Program,

" efforts will be made to ensure that corrective maintenance will not compromise the qualification status of the equipment identified on +he Equipment Moster Lists". Equipment within the scope of environmental qualification is identified on the plant work requests during planning of the work activity.

Planning is performed by a plant staff group to ensure that the maintenance activity will _ not compromise the qualification status of the equipment identified on the Equipment Master List.

For such equipment, a statement on the plant work request clearly states that the equipment 13 environmentally qualified.

In addition, the journeymen performing the work are routinely trained to return such equipment to its original installed configuration.

Also, drawings are used for maintenance on cables and pd conduits that provide visual installation details to ensure resealing of the cables to their original configuration.

Consequently, equipment is returned to its original configuration unless work is being performed as a result of a design modification, k

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g 0057665 ATTADMENT 3 WESTINGHOUSE AFFIDAVIT REQUESTING IWORMATION IN SUPPLEMENTS 1, 2, 3 and 4 TO BE WITHHELD FROM PUBLIC DISCLOSURE O

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AW-80-27 IhU AFFIDAVIT 0057668 CCriMCNWE.ALTH OF FEMNSYLVANIA:

ss COUNTY OF ALLEGHEMY:

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Before me, the undersigned authority, personally appeared Rober: A. Wiesemann, who, being by me duly sworn ac:ording to law, deposes and says that he is authorized to execute this Affidavit en behalf of Westinghouse Electric Corporation (" Westinghouse"). and that the averments of fact set forth in this Affidavit are true and correct to the bes*. of his knowledge, in'fbrm.ation, and belief:

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Rocert A. Wiesemann, Manager Regulatory and Legislative Affairs

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Sworn to and subscribed-this/[ day

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before of

_ 1980.

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[ Notary Public, I -

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005766.7 (1)

I am. Manager, Regulacery and Legislative Affairs, inj the Nuclear-

- Tecnnolocy Division, of 'destinghouse Electric-Corporation and _ as-a suen, I.. ave been specifically delegated the function-of-reviewing j

the proprietary information sought to be withheld from public-dis-4 closure in: connection with nuclear power-plant licensing or rule-making proceedings, and am authorized to apply for its witnholding l

cn benalf of the' Westinghouse Water Reactor. Divisions, i-i l

(2)

I am making tnis Affidavit,in conformance:with the provisions of 10CFR Section.2.790 of the Comission's regulations.and in con--

-function with the-Westinghouse application-for withholding ac-companying this Affidavit.

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(J)

I have personal knowledge oft;th'elcMteria' and procedures utilized.

g by Westinghouse Nuclear Energy Systems in

designating information-

- as a trade secret,- privileged or as confidential comerical or-

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I financial information.

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(4)

Pursuant to the provisions of paragraph :(b)(4)fof Section'2.790 -

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of the Comission's regulations, the following is-furnished for l

consideration by.the Comission in_ determining whether the in--

i-formation sought-to be withheld-from public disclosure should be-i-

withheld.-

(i)

The _information' sought to be-withheld from public disclosure is owned and has been held in confidence by Westinghouse.

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b (ii)

The infermation is of a type customarily. held in confidence by-Westinghouse and-not custemtrily. disclosed to the public.

Westinghouse has a rational basis for determining;the: types of infomation customarily held-in confidence 'by_ it and, in-j that c:nnection, utilizes 4, system to determine _ when and

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whetner to hold certain types of-information in confidence.-

i The apolication of.that system and the substance ofLthat system constitutes Westinghousc policycand provides the ratienal bas _is required.

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~4 Under that system, infomation is held-in confidence if it falls in one!cr more of.several-types, the release-of wnich might result in the. loss of. En existing or siotential com-

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_ g. [

r petitive a-intage, as fonows::

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. py*f (a)

The-information reveals the distinguishing: aspects of_

-l a-process (or component, structure, tool, method, etc.-)

where prevention of Lits use-by:any of Westinghouse's competitors without license from Westinghouse 1consti-tutes a competitive economic-advantagetover. ether:

companies.

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(b)

It consists of supporting data, including-test data,'

relative.to a procats (or. component istructure. tool _,.

method, etc.), -the application of whichidata secures a-1 competitive'economiciadvantage,;e.g., by optimization

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'or_ improved marketability, j

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_.__~________li._____u.m__m._.______

4-AW-80-27 0057agy (c)

Its use by a competitor would reduce his expenditure' of resources or improve his competitive position in the design,: manufacture, shipment, installation, assurance:

of quality, or licensing a similar product.

1 (c)

It reveals cest' or price information, production cap-acities, budget levels, or comercial-strategies of Westinghouse, its' customers or supeliers.

(e)

It reveals aspects;of past, present, or future West-4 inghouse or customer funded development plans and-pro-grams of potential; commercial value to Westinghouse.-

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(f)

It contains patent bTe ideas, for which patent pros taction may be desir&ble.

(g)

It is not. the property of Westinghcuse, but must be.

1 treated as proprietary by Westinghouse according to agreements with the-owner.-

q There are sound policy reasons'behind the Westinghouse system which. include the following:

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(a) - The use of such. infomation by Westinghouse gives Westinghouse-a competitive advantage over its:com-petitors.

It is, therefore, withheld from disclosure-k

' to protect the Westinghouse-competitive position.

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g. AW-30-27' A(

.0057070;.

U (b)

It is information wnich is marketaole in many ways.

The extent to which such"information is available to competitors diminishes the Westinghouse aoility to-

. sell products and services involving-the'use of the information.

(c)

Use by our competitor would put Westinghouse at a-competitive disadvantage by reducing his expenditure of resources ~at our expense.-

(d)

Each component of proprietary information pertinent; to'a particular c:mpetitive a'dvantage:is potentially

.as valuable as the total competitive advantage.

If.

- competitors acquite components of-proprietary infor-C.

mation, any one compenent may be the key to:the entire a

Q pur:le.. thereby deprfving-Westinghouse-of _ a competitive advantage.

(e)

Unrestricted disclosure would jeopardize-the position.

of prominence of Westinghouse:in the world' market, and thereby give a market advantage.- td the.: competition in those countries.

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V (f)

The Westinghouse capacity to invest corporate assets in research and' development depends -upon the suecast in obtaining = and' maintaining-a- comoetitive advantage.

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- Awes 0-27 0057671

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'iii)- The information is being transmitted;to the. Commission in.

4 confidence and,: und - the.;rovisions of 10CFR Section 2.790, it is to be received in ecnfidence by.the Commission.

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(iv)

The information sought to be protected. is not' available in-public sources to the' bestf of our knowlecge and belief.

(v)

The proprietary information sought to be. withheld in this o

i submittal is that whichls appropriately marked in the attaen-

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j ment to Westinghouse Letter No. NS-TMA-2257, Andersonito i

Miller, dated June 16, 1980 concerning the Westinghouse Equip-d ment Qualification Program to address RegulatoryLGuices 1.89 and1.100.

The letter and attachment are being submitted to 1

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complete the information provided in WCAp-8587,. Supplement-1, which was requested by the NRC via PBS Standard" Question.No. -4,

" Environmental-Qualification of Class-1E Equipment."

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This-information enables' Westinghouse ~ to:

(a)

Develop test inputs and procedures to satisfactorily:

verify the designLof Westinghouse suppli'ed equipment'.

(b)- Assist its customers to obtain licenses.

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Further, the information has substantial commercial value as follows:

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(a)

Westinghouse can sell the-use of. this information to-l

- customers.

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-(b)

Westingneuse uses the information to verify the cesign of equipment which is sold to custemers. -

(c)

Westinghouse can sell testing services based upon the experienca gained and the test equipment and metnocs developed.

Public disclosure of this information is likely to-cause substantial harm _to the competitive position of Westinghouse because it would enhance' the; ability of_ competitors to design, manufacture, veMfy, and sell electrical equipment for ccm-mercial power reactors without comensurate. expenses.

Also, public disclosure of the information would enable others t' '

havingthesameorsimiYar' equipment-tousetheinformation-to meet NRC requirements for_ licensing documentation _witncut--

O aurchasins the r4 ht==. use the iaformation.

The development of the equipment described in part by the infomation is the result of_ many years of development by-Westinghouse and the expenditure;of a-considerable sum of money.

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This could only be duplicated by-a competitor -if he were -

to-invest similar sums"of money and provided he had the appropriate talent available and could-somehow obtain-the-

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requisite; e.tperience.

s Further the deponent sayeth not.

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