ML20112H560
| ML20112H560 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/08/1985 |
| From: | John Marshall COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 9590N, NUDOCS 8501170202 | |
| Download: ML20112H560 (11) | |
Text
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f^N) one First Nationtt Pina. Chicago. lilinois Commonwealth Edison O'
Address Reply to: Post Offica Box 767 Chicage, Illinois 60690 January 8, 1985 Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Units 1 & 2
~
Environmental Qualification of Electrical Equipment NRC Docket Nos. 50-373 and 50-374 References (a):
September 4, 1981 letter from L.O. DelGeorge to A. Schwencer.
(b):
Section 3.11, SER, SSER #1, SSER #2
Dear Mr. Denton:
Commonwealth Edison Company hereby requests an extension on the schedular requiremeats of 10 CFR 50.49(g) for replacement / modi-fication and test completion for specific equipment subject to the environmental qualification (EQ) rule for LaSalle County Station, Units 1 and 2.
Additionally, an extension is also requested on the implementation of a Maintenance and Surveillance Program designed specifically to insure the continued qualification of equipment critical to accident mitigation and within the scope of the EQ rule.
We propose that all equipment will be in full compliance with i-10 CFR 50.49 prior to any unit operation'after November 30, 1985.
l This extension is required for various types of equipment l
which are discussed individually in the attached report.
Reasons L
for not meeting the original March, 1985 deadline are also provided therein but generally include factors such as test complications, long procurement lead times, and installation complexities.
It should be recalled that the original EQ requirement for LaSalle was
-to satisfy the criteria set forth in the DOR Guidelines.
In 1981, however, this requirement was changed to the Category II criteria of NUREG 0588.
This regulation change had substantial impact and is the principle reason why the requalification program subsequently undertaken was so extensive in nature.
i p,iSoS*ofodki i
H. R. Denton January 8, 1985 Statistically, the degree of ccmpliance for each unit is tabulated below:
Unit 1 Unit 2 Total no. of components 741 745 requiring qualification to 10 CFR 50,49 requirements Total no. qualified at present.
473 495 Total no. which will be qualified 562 656
-prior to unit operation after March 31, 1985 From the above, it can be seen that Unit 1 will be 76% complete and Unit 2 will be 88% complete prior to any unit operation after March 31, 1985.
Commc.nwealth Edison has been fully committed to compliance with 10 CFR 50.49.
This is evidenced by the progress made to date and the high cegree of compliance achieved thus far.
A Jus.tification for Interim Operation was submitted per Reference a) and remains in effect except that it does not address equipment subsequently determined to require qualification per 10 CFR 50.49.
-In these limited cases, a justification is included in the attachment to this letter.
Reference b) provided the Commission's acceptance of that submittal.
If there are any further questions regarding this mattter,_
please contact this office.
Very truly yours,
%.33.'W1 J.G. Marshall Nuclear Licensing Administrator 1m Attachment 9590N
F Environmental Qualification Request for Extension LaSalle County Station Units 1 and 2 Namco Limit Switches The Namco switches themselves are environmentally qualified but they have an installation constraint: in areas potentially subject to steam conditions, the switch housing must be sealed against the environment.
Prior to fuel load on Unit 1, a potting compound was installed to provide the seal and was subsequently subjected to a qualification program, which proved that it was not an adequate moisture barrier.
Prior to fuel load on Unit 2, a qualified seal assembly was installed so that no further action is required there.
There are limit switches on eight valves in Unit 1 which cannot be sealed prior to March 31, 1985 because they are inaccessible during plant operation.
All affected applications are in the Nuclear Boiler System.
An extension is requested on the installation of these seals until the first refueling outage which is scheduled for September, 1985 but in no case will start later than November 30, 1985.
Under the assumption that the potting compound would later be determined to be qualified, these switches were treated as qualified in the Justification for Interim Operation submitted previously.
Because that status cannot be substantiated, a justification is provided below.
Justification for Interim Operation 1B21-F022A,B,C,D; IB21-F028A,B,C,D The limit switches on these valves indicate MSIV position.
Actuation of the MSIV's is not dependent upon these limit swtiches, nor does failure of these limit switches affect MSIV operation.
These limit switches are provided to initiate a scram signal to anticipate the pressure / flux scram signals which will occur following MSIV closure.
SOR, Inc. Pressure Switches Pressure switches manufactured by SOR, Inc. will replace unqualified Barksdale and Static-0-Ring switches.
Much of this work will be completed prior to March 31, 1985 either during plant operation or during a planned outage on Unit 2.
The affected systems are:
Nuclear Boiler; Reactor Protection System.
All Unit 2 installations will be completed prior to the first start-up after March 31, 1985 so that no extension is required.
However, an extension is requested for the installation of forty-six (46) switches into Unit 1.
This work must be done during an outage either because a half-scram situation would be created or because a shutdown is required by procedure.
This modification will be implemented during the first refueling outage which is scheduled to begin in September, 1985 but in no case will start later than November 30, 1985.
l
. All applications for which an extension is requested with the exception _of the following, were addressed in the Justification for Interim Operation submitted previously to the Commission which remains in-effect.
The following applications are the exception to
-this statement:
IB21-NO39 A, B, C, D, E,F, G,H, J,K, L,M, N, P, R,
S,-U, V.
These applications were determined to require qualifica-tion subsequent to the submittal of the Justification for Interim Operation to the Commission in September, 1981.
A justification of these specific applications has been prepared and is provided as Attachment A to this report.
Limitorque Valve Motor Operators In order to create a qualified configuration, motors with B-class insulation will be replaced with comparable motors which.
have. type-RH insulation.
This upgrade program covers forty-two (42) operators in Unit 1 and fifty (50) in Unit 2, all located outside of primary containment.
The affected systems are:
High Pressure Core Spray; Residual Heat Removal; Low Pressure Core Spray;z Main Steam Isolation Valve Leakage Control; Reactor Core Isolation Cooling; Primary Containment Ventilation; Primary Containment Purge.
An extension until November 30, 1985 is requested for both units due to long procurement lead times.
The motors have'been ordered but will not be available until April, 1985.
With the exception of only three applications in Unit 2, all other motor replacements can be completed during plant operations within the Technical Specifica-tion' Limiting Condition for Operation.
This effort will be started following receipt of the hardware and will be completed prior to any unit operation after November 30, 1985.
For the-three Unit 2 applications which require a unit shutdown, the replacement will be completed ~ during an unplanned outage of ' sufficient length or during i
- a. forced outage, as required, in order to meet this deadline.
All applications for.which an extension is requested were addressed in the-Justification for Interim Operation previously submitted 1to the Commission,-which remains in effect.
Valcor Solenoid Valves Two (2)' applications per unit require the following modification in order to attain a qualified configuration:
a control box will be added to the circuit which will reduce the coil holding voltage, thereby relieving-the heat rise due to coil energization.
Both applications are in the Drywell Pneumatic System (Instrument-Nitrogen).
o e This modification will be implemented in Unit 2 prior to first start-up after March 31, 1985 so that no extension is required.
An extension is requested, however, for Unit 1.
This extension is required because the work must be donc during a plant shutdown and can best be completed during the first refueling outage which is presently scheduled for September, 1985 but in no case will start later than November 30, 1985.
The applications for which this extension is requested were addressed in the Justification for Interim Operation submitted previously which remains in effect.
SOR, Inc. Differential Prcssure Switches SOR dP Switches will replace Barton switches which are presently installed and are unqualified.
The following systems are affected:
Nuclear Boiler; Leak Detection.
Many of these replacements can be inplemented during plant operation and will be completed prior to March 31, 1985.
Applications which require a plant shutdown for modification because they create a half-scram will be completed on Unit 2 prior to-first start-up after March 31, 1985 so that no extension is required.
An extension is requested, however, on the implementation of this replacement for twenty-six (26) applications on Unit 1.
This work can best be completed during the first refueling outage which is presently scheduled for September, 1985 but in no case will start later than November 30, 1985.
The applications for which this extension is requested were addressed in the Justification for Interim Operation submitted previously, which remains in effect.
Siemens Blower-Motor In order to create a qualified configuration, this blower-motor requires a replacement of a bakelite fan blade with an aluminum substitute.
This part upgrade effectively eliminates the weak link and yields a qualified unit.
The affected system is Main Steam Isolation Valve Leakage Control.
This modification has been inplemented in Unit 2 so that no extension is required.
An extension is requested, however, for implementing this upgrade in three applications in Unit 1.
This modification can best be completed during the first refueling outage because of the extensive testing which must be done to verify the adequacy of the installation.
The outage is presently scheduled for September, 1985 but in no case will start later than November 30, 1985.
^
. The applications for which this extension is requested were addressed in the Jastification for Interim Operation submitted previously, which remains in effect.
S&K Flow Element In order to establish a qualification data base, a test was sponscred at Wyle Laboratories.
This test demonstrated that the flow element produced erratic output when exposed to high temperature anticipated following a DBA.
This anomalons behavior was discovered in July, 1984.
Subsequently, a unique analysis was begun to try to establish a less severe qualification profile.
This effort was discontinued in October, 1984 when it proved not to be fruitful.
Recently, evaluation of a product manufactured by FCI has been initiated.
This element is generically qualified and appears to meet all LaSalle-specific requirements, although evaluation is still in progress.
Because of the recent discovery of this problem, a resolution has not been formalized but will be in the near term.
Should this decision be replacement with new instruments from FCI, it is not likely that hardware can be delivered prior to March, 1985.
An extension is requested for both Units 1 and 2 until the first start-up after November 30, 1985 on the qualification of four (4) elements used in the MSIV-LCS system.
This extension is warranted because of the late date at which original qualification efforts were determined to be insufficient and the procurement lead time associated with the acquisition of new hardware.
The applications for which this extension is requested were addressed in the Justification for Interim Operation which was submitted previously to the Commission and remains in effect.-
Delphi Hydrogen-Oxygen Analyzer Panel In order to achieve a qualified configuration for the two analyzers per unit, the following steps are required:
1.
Potentiometers presently mounted on the rack will be relocated to the control room for accessibility to the operator.
2.
Pump diaphragm must be upgraded.
3.
Heat tracing associated with the analyzer system will be upgraded to an environmentally qualified system.
4.
The catalyst will be replaced with an improved i
catalyst which is not subject to iodine poisoning.
e
. It is anticipated that some of the above steps can be completed prior to March 31, 1985 although the vendor's catalyst test is still in progress.
Because of long procurement lead time associated with the heat tracing system, this portion of the effort will not be completed prior to March.
An extension is requested on the implementation of the above measures for both Units 1 and 2 until November 30, 1985.
The installation will be completed on Unit 1 during the first refueling outage presently scheduled for September, 1985 but which will start no later than November 30, 1985.
The Unit 2 work will be completed either during an unplanned outage of sufficient length or a forced outage, as required, in order to meet this schedule.
The applications for which this extension is requested were addressed in the Justification for Interim Operation submitted previously which remains in effect.
Atomics International Hydrogen Recombiner In order to create a qualified configuration for the recombiner used in each unit, the power cabinet and sensitive devices mounted on the skid will be relocated to a mild area.
The only part replace-ment which is required involves replacement of the thermocouples.
An extension is requested on the implementation of this modification in each unit until November 30, 1985.
This is warranted partly because of difficulty in procuring the required thermocouples but also beccuse of the complexity of the intallation.
Much of the work can be completed during plant operation and will be initiated during the interim time period with completion no later than unit operation following November 30, 1985.
The applications for which this extension is requested were addressed in the Justification for Interim Operation submitted previously which remains in effect.
Systems Control DC Motor Control Center In order to qualify the one application per unit subject to qualification requirements, a qualification program was sponsored at Wyle Laboratories.
Efforts to coordinate this test began in 1982 but because of the extensive analysis required, this effort spanned a two year period.
In the original effort, a problem was encountered with the electrical interlocks.
A follow-on effort has been completed on an improved interlock so that a qualified configuration can be achieved by upgrading the installed interlocks.
The MCC itself is in the DC Distribution System but it powers motor-operated valves in the Reactor Core Isolation Cooling System.
, Because of the extensive post-modification testing which must be done in order to verify proper installatinn, this work should be performed during plant shutdown.
The Unit 2 work will be completed during a planned outage scheduled to start no later than March 31, 1985 so that no extension is required.
An extension is requested, however on completing the Unit 1 work until the first refueling outage which is scheduled for September, 1985 but in no case will start later than November 30, 1985.
The application for which this extension is requested was addressed in the Justification for Interim Operation submitted previously which remains in effect.
Klockner-Moeller AC Motor Control Center In order to establish qualification data for the six applications per unit subject to 10 CFR 50.49, a qualification program is in progress at Wyle Laboratories.
Efforts to coordinate this test began in 1982 but, because of the extensive analysis required, this effort spanned a two year period.
Testing began in September 1984 but, due to the long aging times and detailed func-tional testing of so many devices, this test will not be completed until September, 1985.
Assuming that no unforeseen failures occur to extend test completion, this effort will be completed prior to November 30, 1985.
The test models the present installation so that no field modifications are anticipated.
The MCC's themselves are part of the Auxiliary Power System but they power equipment in the following systems:
Switchgear Heat Removal; Hydrogen Recombiner; Containment Monitoring; Nuclear Boiler; Primary Containment Purge; Reactor Core Isolation Cooling; Residual Heat Removal; Reactor Water Clean-Up; Primary Containment Ventilation; Reactor Recirculation; Standby Liquid Control; Control Rod Drive Hydraulic (Scram Discharge Volume); Main Steam Isolation Valve Leakage Control; Reactor Building Closed Cooling Water; Low Pressure Core Spray; Reactor Building Equipment Drain; Diesel Fuel Oil, Core Standby Cooling; Reactor Core Isolation Cooling; Standby Gas Treatment.
The applications for which this extension is requested were addressed in the Justification for Interim Operation submitted previously, which remains in effect.
Magnetrol Level Switch Qualification will be achieved through a combination of test and partial upgrade.
A qualification program was sponsored by CECO and is in progress at Wyle Laboratories; it will be completed prior to March 31, 1985.
Based on recommendations from the vendor, the test sample represents an upgraded version of the switches presertly installed.
The upgrade involves only replacement of the micr, switch and head gasket.
An upgrade of the installed hardware will be implemented in order to attain a qualified status.
r I
l Eight applications per unit are involved.
They are part of the following systems:
Control Rod Drive Hydraulic Control; High Pressure Core Spray.
Modification of any of the affected instruments during unit operation will result in either a half scram or entry into a Technical Specification Limiting Condition for Operation of insufficient duration to complete the required work and post-modification testing.
Therefore, a unit outage is required in order to complete this work.
It is not anticipated that materials will be available prior to March 1, 1985.
Although efforts to procure the required parts had been started in August, 1984, a delay due to continued QA review of the vendor has impeded the issuance of a purchase order.
Accordingly, an extension is requested on the implementation of this modification in both units until first unit operation after November 30, 1985.
All applications for which this extension is requested were addressed in the Justification for Interim Operation submitted previously which remains in effect.
General Electric Terminal Boards These types of terminal boards are used in eighteen various local panels per unit which may have to function while subject to post-DBA environments.
In order to qualify this terminal board, various electrical devices were wired into representative circuits and subjected to a qualification test series at Wyle Laboratories.
The test was recently completed and a review of the data is in progress.
Because of the detailed study which must be made to evaluate the data on leakage current effects, a decision on the acceptability of the terminal boards is still pending.
Under the conservative assump-tion that field modifications may be required, which is indicated based on preliminary review, an extension until November 30, 1985 is requested for both units.
Corrective actions, if any, will be implemented by that deadline.
The applications for which this extension is requested were addressed in the Justification for Interim Operation submitted previously and remains in effect.
Level Transmitter / Switch Presently installed in six applications per unit are Barton 760 level transmitter / switches.
In order to replace this with qualified hardware, a Rosemount 1153 transmitter and an SOR 103 dP switch will replace one Barton instrument.
Both of these new instruments are fully qualified.
All affected applications are in the Nuclear Boiler System.
i
, Some of these replacements can be implemented during plant operation and will be completed in both units prior to March 31, 1985.
For four applications, however, the work must be done during an outage because replacement would initiate a half scram if done during operation.
The Unit 2 work will be completed during a planned outage scheduled to start no later than " arch 31, 1985 so that no extension is required.
An extension is requested, however, for installation of the hardware for the four Unit 1 applications until the first refueling outage, which is scheduled for September 1985 but in no case will start later than November 30, 1985.
The four applications for which an extension is being requested were addressed in the Justification for Interim Operation submitted previously and remains in effect.
General Electric Sensor & Converter This type of radiation detector is used in eight applications per unit in the Process Radiation Monitoring System.
In order to qualify this instrument, a qualification test was sponsored at Wyle Laboratories.
This test demonstrated that the instrument possessed a temperature threshold above which its output became erratic.
Because four applications per unit may potentially be subject to temperature extremes above this threshold, insulation will be installed as a thermal shield.
Additionally, for all applications, the GM tubes will be replaced so as to assure a uniform installation.
Because these instruments are inaccessible during normal operation, the modification must be completed during an outage.
The Unit 2 work will be completed during a planned outage scheduled to start no later than March 31, 1985 so that no extension is required.
An extension is requested, however, on completing the Unit 1 work until the first refueling outage which is scheduled for September, 1985 but in no case will start later than November 30, 1985.
l The applications for which this extension is requested were addressed in the Justitication for Interim Operation submitted previously which remains in effect.
9590N
COMMONWEALTH EDISON COMPANY ATTACHMENT A COMPONENT APPLICATION STATEMENT i
Component B21-NO39A, B, C, D, E, F, G, H, J,K, L,M, N,
P, R, S,U,V These Barksdale BIT-M12SS-GE reactor pressure components are located in the reactor building in environmental zone H4A.
- Hence, these components are exposed to a harsh environment only for the d
Instrument Line Break Event and high radiation from the LOCA inside containment.
The impact of component failure is considered only for these events.
(a) Component Function These compoaents which are located in Division I of the Auto i
Depressurization System are used to sense reactor pressure and will initiate the safety / relief valve (NO39A, B, F, G, H, J, K, L,M,N, and P) and ADS valve (NO39C, D, E, R, S, U, and V) i function for vessel depressurization, j
(b) Effect of Component Failure The failure of these components will not preclude achieving the six safety objectives, namely safe shutdown, containment isola-tion, core coverage, RHR, containment integrity and effluent i
control.
Failure of these components will affect the opreation of a given ADS or SR valve, and disable the Low-Low set arming function.
j (c) Impact on Other Systems The sole function of these components is to initiate opening of i
l an ADS or SR valve and arming of the Low-Low set function.
No
~
other sytsems are affected by their failure.
4 (d) Operator Action The safety / relief valve system is not required for these events which are depressurization events.
Division II of ADS is available as well as HPCS if necessary.
No operator action is required to meet the six safety objectives.
l
REFERENCES:
P&ID:
M-23, Sheet 5 Schematic:
1E-1-4201 9590N