ML20126L166

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Forwards Supplemental Info Addressing Open Items Defined in Section 1.8 of NUREG-0519,facility SER
ML20126L166
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 03/27/1981
From: Delgeorge L
COMMONWEALTH EDISON CO.
To: Youngblood B
Office of Nuclear Reactor Regulation
Shared Package
ML20126L169 List:
References
RTR-NUREG-0519, RTR-NUREG-519 NUDOCS 8106010415
Download: ML20126L166 (15)


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f"N C:mmenw:alth Edison

~ ) One first Nat onar Piaza. Chicago. nhnois

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3 TJ J'? Address Reoly lo: Post Othee Box 767

\ / Chicago. Ilhnois 606??

2 March 27, 1981 Mr. B. J. Youngblood, Chief Licensing Branch fl o . 1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

LaSalle County Station Units 1 and 2 Supplemental Information in Response to NUREG-0519 Open Items NRC Occket Nos. 50_373/374 -

% l References (1): L. O. DelGeoge letter to B. J. Youngblood dated March 6, 1981 l

Dear Mr. Youngblood:

The pyrpose of this letter is to provide supplemental ,

information which adoresses the open items defined in Section 1.8 of the LaSalle County Safety Evaluation Report (SER), NUREG-0519. Each of these items with the exception of item ) is addressed in an enclosure to this letter. With respect to item I, the required occumentation of conformance to the safety significant regulations was submitteo in Reference 1 If you have any questions on the attached materials, please

, direct them to this office.

Very truly y urs, L. O. D e 1 %3 o rg e Nuclear Licensing Aoministrator l Enclosure cc: NRC Resident inspector - LSC5

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Enclosure 1 1

-Item 2. .Small Pipe Visual Inspecton During Preoperational Tests 13.9.2.1) J Commonwealth Edison has reviewed the additional

. surveillance recommended by the NRC Staff and with one exception '

will: perform the inspection proposed. A detailed discussion of our planned inspections is presented below.

1. R e a c *. o r pressure vessel level indicator instrumentation lines A visual inspection of vessel level and pressure instrumentaton lines will be'made in conjuction with Startup Test Procedure (STP) 34, " Vibration Measurements." The visual. inspection will be conducted to identify any excessive vibration that could result in fatigue' failure.
2. Main Steam instrumentation lines for monitoring main steam flow l Although Commonwealth Edison has evaluated the performance of this test, it is judged to be impracticable and,.therefore, a comm1tment can not be made.

(a) A meaningful test can not be performed without steam flow.

The environmental conditions including temperature and radiation make it impossible for this test to be performed visually.

(b) Instrumentation of the subject lines can not be achieved without jeapardizing existing test schedules. In this regard, it should be clearly understood that this syctem was never under consideration for vibration monitoring under Preoperational Procedure 14.2-4 5 o r S tartup Tes t Procedure 14.2-130. In fact, the NRC did not raise the possibility of monitoring this additional system until February, 1981, notwithstanding the acceptace by the Staff

< the proposed testing in 1979 Furthermore since the instrument lines in question provide input to op transmitters, were a tailure to occur, the
  • resulting hi-dp signal would result in a vessel isolaion which is an analyzed transient not limiting to the plant design.

For these reasons, it is judged that this test need not be performed, due both to the fact that it does not add to the safe operation of the plant, and its addition at this time imposes an undue burden.

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3. Reactor Core isolaton Cooing Lines on the RC IC s team line outsiae containment.

The requested visual inspection of these lines to identify any excessive vibration is-currently planned as a-part of the Orywall Piping Vioration Test (see Table 14.2-136).

.4. -Control Rod Drive (CRO) lines inside containment The requesteo visual inspection to identify any' excessive vibration will be performed for all CR0 withdraw and insert lines insice contain' ment in conjunction with Startup Test Procedure 34, " Vibration Measurements".

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Enc losure 2 l

l Item 3. Dynamic Qualification-(3.10)

All safety-related equipment covered by the SQRT program were covered by an' extensive dynamic qualification program. this complex program included many activities that may be summarized as l

follows:

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1. ' Comprehensive evaluations for~the original seismic qualifications in view of the new acceptance criteria based on- t

. :a. All new loading combinations (including LOCA and pool

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dynamic loads).

l b. U.S. MRC Regulatory Guide 1.92

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c. IEEE 345-1975

~d. U.S. NRC Regulatory Guide 1.100

e. 0.S. NRC SRP -3.9.3 and 3.10
2. Requalificat' ion efforts, using testing, analysis or both, to

. demonstrate the acequacy of equipment for which the original seismic avalificatons did not meet the requirements of the new acceptance criteri).

3. H ardwa re . de s i gn mo'a i f ic a t i ons f o r equ i pmen t which failed to meet ,

I the requirements of the new acceptance criteria.

4. ' Replacement of equipment which cannot be modified to meet the new acceptar.ce criteria (this happened only in one case).

Evaluation Results The evaluation process was completed a year ago and all pieces'cr equipment for which the qua lit ication did not meet the new criteria . vere ioentified. A study was made to categorize areas of deflCiency and develop a plan cf attack to address these ceficiencies. ,

Requalification Efforts I. Analysis

a. 300 reports were revised to include the new loads. This work has been completed.
b. 30 reports including new detailed dynamic analyses for all new requirements were completed.

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c. Fatigue evaluation for LPCS pump and the RHR Heat Exchanger was conducted for the extended duration of the pool dynamic loads and completed.
d. A valve flexibility study to Justify all amplificaton factors used in the qualitication is in progress.

II. Testing

a. Laboratory Tests Complete new qualification tests were (and are being) conducted for 17 peices of equipment (mainly electric) and 30 pieces of instrumentation equipment.
b. In-plant Testing

.i) Impedance testing was completed for 16 pieces of equipment mounted on pipes and on the floor. The evaluation.of the data'is in progress.

ii)' SRV testing - 5 floor mounted equipment plus tew pipe mounted equipment will be monitored during the test.

Design Modification A number of design modifications were required and implemented in the cases of four valves, hydrogen recombiner and numerous HVAC hangers to 9 duce the severity of the input to dampers. A few aoottional i cifications are being studied but are not finalized yet.

Equipment R4ulacement Certain sub-components of the RCIC pump turbine have been replaced. '

This is the only case to be reported at the present time, but this aption ;s stil' Ivailable it needed for use in the future.

STATUS 95% of dOP equipment qualifications are completed. The 5% remaining is in progress and scheduled to be completed by the end of May, 1981; except for. valve operators which may extend to June 1981. 80%

of NSSS equipment qualifications are completed. The 20% remaining ,

is in progress and will be completed by May 1981 except valve operators which may be extended to June 1981.

Conclusions All equipment will be qualified to meet the new acceptance criteria cy .iune-198'.

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1 Our equipment qualification demonstrates structrual integrity, functionability and operability.

j Our equipment qualifications has the following built in conversatism l and/ir margins:

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a) use of low damping values (1% & 2%)

b) use of racial resultant of the pool dynamic ioads in both horizontal directions c) use of response spectrum curves i n lieu of time histories c) use of peak broadened response spectrum curves for all dynamic loads.

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Enclosure 3 Item 4 Environmental Qualification (3.11)

Commonwealth Edison has idenitified the electrical,

' equipment-at LaSalle Station Units 1 and 2 which may experienc2 HARSH environments due to Loss of Coolant Accidents (LOCA) Feedwater Line Breck Outside Primary Containment and High Energy Line Break accidents (HELB). The equipment identified by Edison included:

a. Equipment neeoed to bring the reactor to a cold shutcown condition following the defined accidents.
b. Equipment needed to remove core decay heat to preserve integrity of fission proauct barriers.
c. Equipment that must not fail in manner detrimental to the above two safety functions.

Plant lo.ations and. equipment functions have been idenified i n terms of safety,.i.e., active (must function), passive (must preserve pressure boundary i ntegity), and "important to safety" if the equipment must r<ot function or interact deleteriously with safety equipment.

<A review of all LaSalle County 5tation safety-related electrical equipment in. harsh environments was completed against the 00R Guidelines-(Guidelines for Environmental Qualification of Class'IE

- Electrica'i Equipment in Operating Reactors), and was submitted ~to the NRC Staff on October 31, 1980.

The results of this review showed that approximately 85% of i tems in harsh-environments were qualified to the 00R Guidelines, approximately 10% were awaiting documentation and approximately 5%

were;uncergoing E.Q. testing.

' The conclusions evident from this original comparison to 00R Suiceliset'*ere-as follows:

a. All Class lE equipment was environmentally qualified with occumented records, or was qualfied but wri. ten reports were still being assemblea, or the devices were undergoing E.Q. testing.
b. .The only exception was the change out of a limit switch to obtain a suitaole qualified model.

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. Based on the results of the E.Q. comparison 1to 00R Guidelines, a

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plant _ systems, review was made for all. systems employing Class lE

' cevices whose E.Q. documentation was not completed. This systems review-would,conclud that the required plant safety functions were invalidated by failure of'any individual item on this incomplete

-documentation list._-The bases-included the following: functional time: analysis, similarity analysis, knowledge'of test results net

,' yet in_ report format, ana comparison analyses.

Suosequent to this original eva~1uation against the 00R Guidelines,

- but prior to the NRC Staff directive of February 13, 1981 to perform th'ereview to NUREG-0588, Commonwealth Edison contracted Wyle Laboratories to upgrace the environmental qualification of Class IE equipment at-La Salle CountyLto the Category II requirements of NUREG-0588 " Interim Staff Position on4 Environment Qualification of Safety-Relatea Electrical Equipment".

The' current'. expanded program'is designed to, reevaluate the

-previously. identified items and through analyses using existing test documentation or through'new testing . achieve-full' qualification status to NUREG-0588 (Category II) requirements.

' Plant' environments have been tabulated for equipment l o c a t i o.o s .

These environments have been grouped into a number of bounding environmantal envelopes for the purpose of simplifying toe qualification analysis and testing efforts.

Equipmentfitems have been grouped by Manufacturer and Model number into equipment lists; the HARSH environemnt zone shave 88 separate list entries. Ninety-five list ert<ies are associated with NON-HARSH environemental1 zones.

Extensive' data search through environmental qualification reports ,

and records at Wyle Leboratories and other sources plus the vendors

' engineering record files is nearly completion. A n a l y t t,c a l avaluati3ns on aging are underway on 49 of the 88 list entries.

Qualification assessment files are retained open for receipt of 4 aplicable data until the analytical work is complted. At that time a reccanendation is made for qualification testing to assure f u l '.

compliance witn the NUREG-0588 requirements.

The sequen'ce of indiviaual list entries therefore, produces a sequence of test recommendations. These~ recommendations are reviewed by the utility for test approval or a replacement

-aecision. Test procedures are written for groups of similar equipment where aossible. -These test procedures are amplified into test schedules to assure that effective testing is done on a scheduli which meets the objective dates.

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Major milestones for LaSalle as documented in the L. O. DelGeorge letter to B. J. Youngblood of March 9, 1981, are as follows:

Initial Submittal to NRC of EQ Report October 31, 1980 Completion of Evaluation (Analysis) June 30, 1981 Decision of Last Recommendation July 31, 1981 Completion of Last Test Series May 1, 1982 Final Qualification File Completed June 30, 1982 (Note that the above dates are the completion dates for the final activity of that action category).

Analytic 11 techniques used in Reevaluation of equipment include:

thermal lag analysis, test duration analysis, degardation equivalency analysis, safety functional time analysis.

Combinations or categories of equipment items into test groups based on environmental profiles enable sequential testing with minimum schedule upset. The sequence of testing includes:

A.) Test Plan (Procedure) 8.) Baseline Functional Tests C.) Radiation Aging D.) Functional Tests E.) Time-Temperature From Aging or Cyclic Aging F.) Functional Test a.) Extreme Environments n.) Functional Tests I.) Seismic Qualfication J.) Functional Test K.) Harsh Environments L.) Functional Test M.) Test Report issued l I

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A meeting with the NRC Staff i s scliedu led for March 31, 1981 to review the existing LaSalle County environmental qualification records in order to clarify the current status of those records for the Staff. It is hoped that subsequent to this i meeting and understanding will have been reached regarding the extent to which docketed qualification summaries require f augmentation prior to the Staff initiating its audit of qualification records.

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a Enclosure 4 Item 5. Fuel Claa Ballooning and Rupture ( 4 . 2 . 3 )_

General Electric Company is currently completing sensitivity studies which bound NUREG-0630 data. This study, utilizing the CHASTE OS (fuel heat-up code), is expected to show a maximum peak clad temperuture (pct) impact of less than 200F. No change in maximum average planar heat generation rate (MAPLHGR) is expected.

The NRC Starf has expressed cuncurrence aith this approach as a basis for resolving the fuel ballooning issue for LaSalle County, and any other BWR NTOL plant ror which the sensitivity study is representative.

A draft copy of this report is expected to be provided the Staff on March 31, 1981, with the formal documentation of the study targeteu for April 2, 1981.

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-w Enclosure 5 Item 6 Compliance with 10 CFR 50 Appendix G(5.3)

The response to this item can be divided into two parts

(1) those requirementsf. stated'in the current provisions of 10 CFR 50 Appendix G which can not be met due to the change in code requirements ~since component purchase, and as such require an exemption from current rules; and (2) full documentation of the i L

bases for conformance to all other provisions.to 10 CFR 50 Appendix l G.  !

With. regard.to the first class, Commonwealth Edison

. submitted in the~L. O. DelGeorge letter to B. J. Youngblood dated.

l February 18, 1981 information aadressing RPV materials. This j information wiLil be formally documente'd in FSAR~ Amendment 56. )

Gith respect to the second. class, Commonwealth Edison has initiated the~ record retrieval and accumentation program necessary

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-to confirm.that no exceptions are required. It is worth pointing out that the regulations do not demand submittal of this information' 'The NRC Staff request.for this information in February, 1981.is a review ratchet that will be dificult to L accommodate quickly. The same. personnel are' heavily involvea in I retrieving and summarizing records relat,ed to the safety-related I. equipment environmental qualification and this work currently is )

assigned the highest priority. '

Although we will submit a-detailed schedule for completion of the Appendix G work by April 15, 1981, depending upon the depth of reporting requireo, this program could take as much as 90 days.

Your assistance in minimizing unnecessary effort would be grectly apprec t'a teo .

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Enclosure 6 Item 7. Criterion 51 of the General Design Critiera (6.2.7)

This program, as first discussed with the NRC Staff on February 6, 1981, is scheduled to be completed by April 10, 1981.

Therefore, we expect to provide the requested assessment accumentation on or betore April 15, 1981.

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l Enclosure 7 I

Item 8. Review of Independent [nspection of Cable Routing (8.4.6) in response to the request for a 10% field audit of cable separation contained in Reference (a), and as committed by

' Commonwealth Edison in Reference (b), the results of the subject l Cable separation: audit'are attached. This audit reviewed a sample l consisting of approximately 10% of the total installed safety-related cables, associated cables and electrical equipment at LaSalle County Station, Unit 1. Specific cables and equipment selected for audit and the criteria to be used to assess the adequacy of the. Installed cable and equipment was delineated by the Architect-Engineer, Sargent'& Lunday ($&L). the actual audit was i performed under the auspices at the Commonwealth Eaison Quality Assurance Department with the technical assistance of S&L represent atives f amiliar with electrical design but not involved in

'the' design.of LaSalle County Station. The actual audit plan is providea as Attachment E7-1.

i The results of the audit were documented in Commonwealth l Eaison-LaSalle County. Audit No.-1-80-63, the aetails of which are on I file at.the. plant site. Included in Attachment E7-2 is a summary of l the auait'results'as well as the engineering evaluation of those results.- This attachment is judgec to provide the necessary documentation to resolve the subject open item.

Peoples dated 1 Referencts (1): .8. J. Youngblood letter to D. L.

May 7, 1980.

(2): D.L. Peoples letter to 3. J. Youngblood cated May 27, 1980 i

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Attachment E7-2 LaSalle County Unit 1 Separation Aucit 1-80-63 Summary of desults The audit conducted involved 398 Class lE cables, and conduit and 384 associated cable and conduit.. The audit. included a review of these cables for separation and markings as well as related termination requirements; and involved in excess of 10% of the-total-cables included in the 22 safety-related systemse selected for audit.

The audit resulted in 3 f indings and 1 observation all of ,

I which were' determined upon investigation to be of an insignificant nature. 'These results,Lthe subsequent evaluation performea and  !

subsequent actions taken are providea in LaSalle-Q.A. Surveillance

. Report tio. 81-79, 81-94, 81-97 and 81-101 which are attached.

It should be clearly noted that after_ this very thorough:

aucit only one-(1) verified violation of established separation criteria was. identified. This isolated deficiency, discussed in greaterfdetail in Surveillance Report No. 81-97 has been corrected.

the' remaining deficiencies can be broken down into three categories, all effecting cable or conduit marking: (1) correctible deficiencies due to broken, misplaced, illegible or improperly taged components; (2) apparent deficiencies resolved after engineering review 1to be within the established aesign criteria; such as tag location on flexible conduit, associated cable taping and associated cable bu idling; ano (3) auditor errors reconciled after resurveillance.

The verified deficiencies, being all related to cable marking do not effect the safe operation of the plant. oCumulatively the deficiencies represent a very small percentage of the total sample addited. Augmented QC surveillance prior to system turnover as & part of the final system walkdown which precedes plant 5tartup will identify all other deficiencies of this type. However, resciution af such deficiencies, though expected prior to fuel loacing will be accomplished as soon as possible. Because caole marking aeficiencies alone do not effect the safe operationa+.e- of the olant, it is judged that such deficiencies can De-remedied fuel load out prior to full power operation.

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