ML20101G828

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Requests Extension for Qualification of Addl Equipment Not Meeting Requirements of NUREG-0588 Until End of Cycle 3 Refueling Outage Scheduled to Begin in June 1985. Justification for Continued Operation Encl
ML20101G828
Person / Time
Site: Sequoyah Tennessee Valley Authority icon.png
Issue date: 12/20/1984
From: Hufham J
TENNESSEE VALLEY AUTHORITY
To: Adensam E
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0588, RTR-NUREG-588 NUDOCS 8412280031
Download: ML20101G828 (7)


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TENNESSEE VALLEY. AUTHORITY CHATTANOOGA. TENNESSEE 374ot 400 Chestnut Street Tc wer II December 20, 1984 Director of Nuclear Reactor Regulation Attention:

Ms. E. Adensam, Chief Licensing Branch No. 4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Ms. Adensam:

In the Matter of

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Docket Nos. 50 -327 Tennessee Valley Authority

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50 -32 8 In accordance with the requirement of 10 CFR 50.49(h), we are providing notification of additional equipment on unit 1 at Sequoyah that has been discovered to not meet requirements of NUREG-0568 for qualification. provides the list of componets and their justification for an.

extension. Enclosure 2 provides the justification for continued operation (JCO) for the componets listed in Enclosure 1.

We are therefore requesting an extension for qualificatien 'of these cocponents for unit 1 until the end.of the cycle 3 refueling outage presently scheduled to begin in June 1985. This schedule relief request is the same as that previously granted TVA on April 11, 1984.

If you have any questions concerning this matter, please get in touch with Jerry Wills at FTS 858-2683 Very truly yours, TENNESSEE VALLEY AUTHORITY l

W.

tl nager i ensing d Regulations Sworn to and subscribpd before me l

this,2Mday of /LM ('4 1984 f?ir ll-

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My Commission Expires #/Y <

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Enclosures (2) cc:

U.S. Nuclear Regulatory Commission (Enclosures)

Region II Attn:

Mr. James P. O'Reilly Administrator -

101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 h

i 8412280031 841220 PDR ADOCK 05000327

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N An Equal Opportunity Employer e

ENCLOSURE 1l Components ~11sted need'a qualified high pressure conduit seal.

'1-ZS-1-181 1-FCV-77-9(LS) 1-ZS-1-182 1-FCV-77-127(LS) 1-ZS-1-183 1-LSV-3-175 1-ZS-1-184 1-FCV-90-108(LS)

.1-LT-3-148-1-FCV-90-109(LS) 1-LT-3-156 1-FCV-90-110(LS) 1-LT-3-164 1-FCV-90-114(LS) 1-LT-3-171 1-FCV-90-115(LS) 1-LT-3-172 1-FCV-313-223(LS) 1-LT-3-173 1-FCV-313-225(LS) 1-LT-3-174 1-FCV-313-230(LS) 1-LT-3-175 1-FCV-313-232(LS) 1-PS-3-165A 1-PCV-1-5(LS) 1-PS-3-165B-1-PCV-1-12(LS) 1-FSV-43-201 1-PSV-1-13B 1-FSV-43-202-1-PCV-1-23(LS) 1-FSV-43-207 1-PSV-1-24B

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1-FSV-43-208 1-PCV-1-30(LS) 1-FCV-61-97(LS) 1-FCV-1-147(LS) 1-FCV-61-122(LS) 1-FCV-1-148(LS) s 1-FCV-61-192(LS) 1-FCV-1-149(LS) 1-FCV-61-194(LS) 1-FCV-1-150(LS)

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1-FCV-62-69(LS) 1-PS-3-160A(TMI) 1-FCV-62-70(LS) 1-PS-3-160B(TMI) 1-FCV-63-71(LS) 1-PSV-1-6B 1-FCV-68-308(LS) 1-PSV-1-31B 1-FSV-68-394 1-PCV-68-334 1-FSV-68-395 1-PCV-68-340A 1-FSV-68-396 1-FSV-68-397 i

In all harsh. environments, the field-installed conduit systems.(including rigid and flexible conduits, conduit boxes, and fittings) for class 1E cables are continuous-(closed) and are designed to be equivalent NEMA 4 watertight. As a result of TVA's evaluation of a nonconformance report (NCR),'

SQN EEB 8403, or certain class 1E devices that are necessary to. achieve safe shutdown, there is a possibility that a qualified seal was not provided at these ' devic s.

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ENCLOSURE 2 JUSTIFICATION FOR CONTINUED OPERATION (JCO)

SQNEEB8403 Discussions of each group below give the justification for continued operation (JCO) until qualified sealing can be installed.

The first group of equipment can be placed in five categories:

transmitters; solenoid valves for air-operated valve control; solenoid valves for process control; pressure switches; and limit or zone switches on valves. The JC0 for each category is given below.

Transmitters LT-3-148

-156

-164

-171

-172

-173 i

-174

-175 The transmitters listed are Foxboro model E-13s. These were tested by i

Westinghouse and reported in NRL-NS-PLL5023 (NEB 820204 200).

l Per this report, the transmitters fail due to terminal corrosion due to j

moisture intrusion in approximately five days when subjected to a LOCA environment. The Sequoyah instruments are installed in a configuration

.f' similar to the test; thus, failure can be expected five days after an accident. These transmitters are used for auxiliary'feedwater control of steam generator level. At the time of failure, the operator can override automatic control using manual control. The manual controls use qualified PAM channels to adjust auxiliary feedwater flow to the stesa generators.

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SQNEEB8403 Sol anaid..Yalv.am.for. Air-Qnaratad.cnntral 1

FSV-43-201

-202

-207 l

-208 These solenoid valves were tested in Wiley Labs Test.I b for LOCA 2

conditions. Per this test, solenoids installed without conduit sealing have an expected life of 4-3/4 days (114.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) and fail by opening the coil. These solenoids are located inside containment and use control air.

An accident which requires the hydrogen analyzers will initiate a phase B isolation which results in isolation of the control air system to containment. The control air system pressure inside contaimaant will quickly drop. By design, the air-operated valves will go to their safe l

positions when the controlling air pressure is lost. The solenoid valve operating time (114.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) will be much longer than the control air system will maintain operating pressure. Thus, the air valve performs its safety function using the solenoid valve and then remains in a safe condition following loss of control air.

PSV-1-6B l

-13B

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-31B These solenoid valves were tested in Wiley Labs Test 17523-1 for LOCA conditions. Per this test, solenoids installed without conduit sealing have an expected lif e of 4-3/4 days (114.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />). Following a Main Steam f

Line Break (MSLB), the plant should be brought to a safe condition within the 4-3/4 days. Further, these valves are grouped with two of the solenoids in one of the valve rooms and two in the other valve room. An i

MSLB will affect at most one-set of these valves. Only two steam generators are required to remove heat from the core. Also, the Wiley test demonstrated that solenoid valves of this type fail by opening of the coil, which by design causes the' air-operated valve to go to its safe condition (repositioning of these valves would not be required). Therefore, event duration would require qualification for a period less than the qualification period of equipment.

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JUSTIFICATION FOR CONTINUED OPERATION (JCO)

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-396

-397 These valves are used in the reactor vessel vent syste,m a nd-were supplied by Westinghouse asaclesa IE quipment. The valves were tested using a seal at the valve for qualification. The Sequoyah installation does not have this seal, but the conduit configuration will drain any moisture away from the valve. Engineering judgment leads to the conclusion that moisture intrusion would not affect the operability of these valves. TVA will install a Conax seal at the next outage to bring the installed j

configuration equal to the tested configuration.

PCV-68-334

-340A These valves were tested using a sealed conduit system. The Sequoyah ir.:tallation does not have the sealed system, but the conduit configuration will drain any moisture away from the valve. Engineering judgment leads to the conclusion that moisture intrusion would not affect i

the operability of these valves. TVA will install a qualified seal during l

the next outage to bring the installed configuration equal to the tested configurtaion.

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-165A

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driven auxiliary feedwater pump. The signal'from these switches cannot be overridden manually. They are installed without a qualified conduit seal.

1-During certain accidents, the failure of these switches could prevent proper operationoftheauxiliaryfeedwatersystem;therefore,continuedoperationof_j L

g, these switches cannot be justified. Since the FSAR does not take any safety j

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credit for these devices, they will be removed from service. During the next outage, they will be replaced with qualifled devices and moved to a less severe;_ ;,y environment.

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JUSTIFICATION FOR CONTINUED OPERATION (JCO)

SQNEEB8403 FCV-90-108 (LS)

-109

-110

-114

-115

-116 These limit switches are on valves for the radiation monitoring system and control the flow of containment atmosphere being sampled for radiation.

The radiation monitor draws a sample from contaiment and returns the sample to contaiment through code class (seismic qualified) tubing. This represents a totally closed system, and no release path exists from containment. Also, the valves have redundant valves located in a low moisture environment. Further, the operator can take manual control to close the valves; thus, bypassing the limit switch circuits.

ZS-1-181

-182

-1 83

-184 These zone switches are on the steam generator blowdown system. The piping in this system is an integral part of the containment boundary; therefore.

no containment release path exists. Also, the redundant valves receive an auxiliary feedwater running signal to close in addition to phase A

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containment isolation, and should remain closed. The operator can take manual control in the event of failure.

FCV-1-147 (LS)

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-148

-149

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-150 These are main steam isolation valve bypass valves used only for system warming. During normal operation the valve handswitch is in the " closed" j

c position; therefore, they could not open.

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these valves are closed. These valves have redundant valves located,g Ey l

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JUSTIFICATION FOR CONTINUED OPERATION (JCO)

SQNEEB8403 FCV-77-9 (LS)

FCV 12 7 These limit switches are on valves in the waste disposal system. These valves are interlocked with a high radiation in containment signal.

Therefore, reset of containment isolation signal would not allow the valves to reopen.

s FCV-62-69 (LS)

-70

-72

-73

-74 These limit switches are on valves for reactor coolant letdown in the CYCS.

These are valves the operator would be required to reopen after resetting the accident signal. These valves are also interlocked with pressuriser level and charging pump running so the operator would have to have correct j

conditions before letdown could be reinitiated.

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