ML20128H524

Safety Evaluation Supporting Environ Qualification of Electric Equipment Important to Safety.Proposed Resolutions for Environ Qualification Deficiencies Acceptable

ML20128H524
Person / Time
Site:	Oyster Creek
Issue date:	05/28/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20128H521	List: ML20128H517 ML20128H524
References
NUDOCS 8505300531
Download: ML20128H524 (13)

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SAFETY-EVALUATIO:

0FFICE OF i:UCLEAR REACTOR REGULATION GPU i;UCLEAR CORPORATI0l4

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.e. . m ,m .n Lm.-i DOCKET ,'0. 50-219 E!?lIR0:3'.5fiTAL QUALIFIC5TIO!! 0F ELECTRIC EQUIP!'. Erit IM?0RTAt;T TO SAFETY I!;TECD'!CTIC!

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Ec:.ipment which is usec to perform a neces:ary safety function cust be demonstrated to be capable of maintaining functional operabili y under all service ccr.ditions pcstulated to cccur during its installed life for the time i is recuired to cperate. This recuirement, which is embodisc in General Design Criteria 1 and 4 of Appendix A and Sections III, XI, and XVII of 4:endix B to 10 CFR 50, is applicable to ecuipment located inside.as well as cutside centainment. !' ore detailed requirements and guidance relating te the methods anc precedures for demonstrating this capability for electrical ecuipment have been set forth in 10 CFR 50.49, " Environmental Qualification of Elect-ic Ecuipment Important to Safety for Nuclear Power Plants," fiUREG-0588,

" Interim Staff Position en Environmental Qualification of Safety-Related Electrical Ecuipment" (which supplements IEEE Standard 323 and various fiRC Regu'.atory Guides and industry standards), and " Guidelines for Evaluating

-Environmental Qualification of Class 1E Electrical Equipment in Operating 4ccters" (DDR Guidelines).

? C5:GFCU?:D Cn February 2, 1979, the I'RC Office of Inspection anc Enforcement (IE) issuec tc'all licensees of operating plants (except those included in the systematic.

evaluation program (SEP)) IE Bulletin (IEB) 79-01, "Enviren: ental

-Qualification of Class IE Equipment." This Eulletin, together with IE Circular 78-C5 (issued on May 31, 197E), required the licensees to perform reviews to assess the. adequacy of their envircnmental cualification programs.

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.On January 14, 1980, NRC issued IEB 79-01B which included the D0R Guidelines and NUREG-0588 as attachments 4 and 5, respectively. Subsequently, on May 23, 1980, Commission Memorandum and Order CLI-80-21 was issued and stated that the DOR-Guidelines and portions of NUREG-0588 form the requirements that licensees must meet regarding en c onmental cualification of safety-related electrical equipment in order to sa:isfy those aspects of.10 CFR 50, Appendix A, General Design Criterion (GDC) 4. Supplements to IEB 79-018 were issued for further clarification and definition of the staff's needs. These supplements were issued on February 29, September 30.,.and G.tober 24, 1980.

In addition, the staff issued orders dated August 29, 1980 (amended in September 1980) and October 24, 1980 to all licensees. The August order racuired that the licensees provide a report, by November 1, 1980, documenting the qualification of safety-related electrical equipment. The October order required the establishment of a central file location for the maintenance of all equipment cualiTication records. The central file was mandated to be

destablished by December 1, 1980. The staff subsequently issued a Safety Evaluation Report (SER) on environmental qualification of safety-related

. electrical equipment to the licensee in mid-1981. This SER directed the licensee to 'either provide documentation of the missing qualification information which demonstrates that safety-related equipment meets the D0R Guidelines or NUREG-0588 requirements or. commit to a corrective action (requalification, replacement (etc.))." The licensee was required to respond to NRC within 90 days of receipt of the SER. In response to the staff SER issued in 1981, the licensee submitted adcitional information regarding the qualification of safety-related electrical equipment. This information was evaluated for the staff by the Franklin Research Center (FRC) in order to:

1) identify all cases where the licensee's response did not resolve the significant qualification issues, 2) evaluate the licensee's qualification

. documentation in accordance with established criteria to determine which equipment had adequate documentation and which did not, and 3) evaluate the licensee's qualification documentation for safety-related electrical equipment located in harsh environments required for TMI Lessons Learned Implementation. A Technical Evaluation Report (TER) was issued by FRC on July 9, 19E2. .A Safety Evaluation Report was subsequently issued to the GPU Nuclear Corporation for its Oyster Creek Unit 1 on November 30, 1982

'with the FRC TER as an attachment.

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A final rule on environmental l qualification of electric equipment important to safety for-nuclear power plants became effective on February 22, 1983. This

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c rule, _ Section 50.d9 of 10'CFR 50, specifies the requirements of electrical equ'ipment important to safety located in a harsh environment. In accordance-with this. rule, equipment for Oyster C?eek Unit 1 may be qualified to the criteria specified in.either1the 00R Guidelines or NUREG-0588, except for replacement equipment. Replacement equipment installed subsequent to February 22, 1983 must be qualified in accordance with the provisions of 10 CFR 50.49, using the guidance of Regulatory Guide 1.89, unless there are sound reasons ~ to 1the' contrary..

A meeting was held with each licensee of plants for which a TER had been iprepared for the staff by FRC in order to discuss all remaining open issues

.regarding environmental _ qualification, including acceptability of the environmental conditions for equipment qualification purposes, if this issue

hadEnot yet been resolved. On December 7, 1983, a meeting was hel'd to discuss

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cGPU's'0yster Creek Unit 1 proposed method to resolve the environmental qualification deficienc.es identified in the November 30, 1982 SER and July 9, 1982 FRC TER. Discussions also included GPU's general methodology for compliance with 10:CFR 50.49, and justification for continued operation for tt.ase equipment items for which environmental cualification.is not yet completed. As a result of this meeting an audit was performed on February 5 and 6, 1985. The audit consisted of a revie'w of ni6e files'containing information'regarding the equipment environmental qualification. Based on-

. -the' results of the audit the staff has concluded that the licensee has demonstrated environmental qualification of equipment items in tFe equ_ipment qualification program to the extent.that the. files reviewed are-l G representative of the remainder of the qualification files. Adequate proof of.

qualification was evident to conclude ~ that the equipment meets the requirements of-10 CFR 50.49.

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The minutes of the December 7, 1983 meetin; and proposed method of resolution for.each of the environmental qualification deficiencies are documented in the December 21, 1984, February 22, and March 15, 1985 submittals from the licensee.

. EGLUATION -

The evaluation of the acceptability.of the licensee's electrical equipment environmental qualification program i,s based on the results of an audit ' review

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performed by the staff of: (1) the licensee's proposed resolutions of the environmental qualification deficiencies identified in the November 30, 1982 SER and July 9, 1982 FRC TER; (2) compliance with the requirements of 10 CFR 50.49; and-(3)' justification for continued operation (JCO) for those equipment items for which the environmental qualification is not yet completed.

Precosed Resolutions of Identified Deficiencies

• The proposed resolutions for the equipment environmental qualification deficiencies, identified in the November 30, 1982 SER, and the FRC TER enclosed with it, are described in the licensee's December 21,.1984, February 22, and March 15, 1985 submittals. During the December 7, 1983 meeting with the licensee, the staff discussed the proposed resolution of each deficiency for each equipment item identified in the-FRC TER and found the licensees approach for resolving the identified environmental qualification deficiencies acceptable. The majority of deficiencies identified were doct. mentation, similarity, aging, qualified life and replacement schedule.

All open items identified in the SER dated November 30, 1982 were also discussed and the resolution of these items has been found acceptable by the staff.

'The approach described by the licensee for addressing and resolving the identified deficiencies includes replacing equipment, performing additional analyses, utilizing additional qualifiYation documentation beyond that

' reviewed by FRC, obtaining additional ot311fication documentation and

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determiningthatsomeequipmentisoutsia(thescopeof10CFR50.49,and therefore not required to be environmental'ly qualified, e.g., located in a mild environment'. We discussed the proposed resolutions in detail on an item by item basis with the' licensee during the December 7, 1983 meeting.

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t Replacing;or exempting equipment, for an acceptable reason, are clearly-acceptabl_e methods for resolving environmental qualification deficiencies. '

The more' lengthy. discussions with the licensee concerned the use-of additional

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analyses 'or documentation. Although we did not review the additional analyses

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.or documentation, we discussed how anaIysis was being used to resolve deficiencies-identified .in the FRC TER, and the content of the additional

documentation in ' order to detennine the acceptability of these methods. The licensee'.s: equipment environmental. qualification files will be further. ,

1 au'ited d by the_sta'ff during fcilow-up-. inspections to be performed by Region

'I,5with assistance from'IE Headquarters and NRR staff as necessary.

Since a significant. amount of documentation has already been reviewed by the -

, staff and Franklin Research Center, the primary objective of the file audit

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willEbe to: verify that they contain the appropriate analysis and other r.ecessary documentation to support the licensee's conclusion that the f eculpment'is qualified. The inspections will' verify that the licensee's program for surveil. lance and maintenance of environmentally cualified

equipment'_is. adequate to assure that this equipment'is maintained in-the as 3 analyze'd or tested condition. The method used for tracking periodic replacement parts,'and implementation of the licensee's commitments and Lactions, e.g., regarding replacement of equipment, will-also be verified.

Based onLour1 discussions with the licensee and our review of its-submittals, we find the-licensee's. approach for resolving the identified environmental

. qualification deficiencies. acceptable.

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.g Compliance With 10 CFR 50.49

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. JInlits December 21,;1984 submittal, the licensee has described the apprcach

used to-identify

equipment within the scope of paragraph (b)(1) of 10 CFR

.50.49,7 equipment relied upon to remain functional during and'following-design basis 1 events.. =The licensee states that the flooding and environmental effects resultin'g from all-postulated design-basis accidents documented in the Oyster p Cre$k1 Final'SafetyAnalysisReport(FSAR),.includingtheLoss-of-Coolant

Accident (LOCAL and the High Energy Line Break (HELB) Accidents, were

considerediin the identification of 'v-related electrical equipment which

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was uto be. environmentally qualified. 'looding and environmental effects r

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6 resulting from High-Energy Line Breaks (HELBs) outside containment were also considered in the identification of this equipment. Therefore, all

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des 1gn-basis events including required accident scenarios at Oyster Creek were considered in the-identification of electrical equipment within the scope fofparagraph-(b)(6of'[CFR50.49(i.e.," Safety-relatedelectricequipment

. . . )."

The licensee's approach for identifying equipment within the scope of paragraph (b)(1) is in accordance with the requirements of that paragraph, and

_therefore acceptable.

The method used by the licensee for identification of electrical equipment-

"within the scope of paragraph _(b)(2) of 10 CFR 50.49, nonsafety-related electrical equiptent whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions, is st. :marized

.below;

1. :A list was generated of safety-related electric equipment as~ defined in-paragraph (b)(1) of 10 CFR 50.49 required to remain functional during or following design-basis Loss of Coolant Accident (LCCA) or High Energy Line Break (HELB) Accidents. The LOCA/HELB accidents are the only desicn-ba'is s accidents which result in significantly adverse environments to electrical equipment which"is required for safe shutdown or accident mitigation. The list was based on reviews of the'.0yster Creek Final Safety Analysis Report (FSAR), Technical Specifici ions, Emergency Operating Precedures, Piping and Instrumentation D'cagrams (P& ids), and Electrical Elementary and Wiring Diagrams:

2; The elementary wiring diagrams of.the safety-related electrical ecuipment identified in Step 1 were reviewed to identify any auxiliary devices electrically connected directly into the control or power circuitry of the safety-related equipment (e.g., automatic trips) whose failure due to postulated environmental conditions could prevent the reoufred operatim of.the safety-related equipment; and

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3. -The operation.of the safety-related systems and equipment were reviewed to identify any directly mechanically, connected auxiliary systems with electrical ' components:which are necessary for the required operation of the safety-related equipment (e.g., cooling water or lubricating or air handling systems, etc.). This in;olved the review of P& ids, and/or component. technical marcuals, and systems descriptions in the FSAR.

'4 Nonsafety-related electrical circuits indirectly associated with the

-electrical equipment were considered by a review of the original

. electrical design criteria for Oyster Creek including the use of applicable industry standards (e.g., IEEE). Properly coordinated circuit breakers and fuses for electrical fault protection are used or, parallel loads will be qualified, or safe' shutdown components were verified to fail in the safe shutdown mode.

The licensee states that the results of the above review indicated'that additional electrical equipment was identified which was not previously included on that " Master List." Therefore, the list of electrical equipment provided in its February 22, and March 15, 1985-submittals is judged by the licensee-to address all electrical equipment within the scope of paragraph (b)(2).of 10 CFR 50.49.

We find the methodology being used by the licensee is' acceptable since it

.provides reasonable assurance that equipment within the scope of paragraph (b)(2) of 10 CFR 50.49 has been identified.

With regard to paragraph (b)(3) of 10 CFR 50.49, th: 'icensee evaluated existing system arrangements and identified equipment or the variables defined in R.G. 1.97, Rev. 3. A report outlining the're.rits of the review, schedules for modifications where necessary, and justification of deviations

.not.recuiring codifications has been submitted to the f!RC for review. Since the report is still under: review by the staff, some of the equipment items with'in the scope of R.G. 1.97 have not been included in the 10 CFR 50.49 sccpe. When the R.G. 1.97 report and equipment lists contained therein have been finalized and ' accepted by the staff, appropriate equipment not already

-in the 10 CFR 50.'49 scope will be added in accordance with the R.G. 1.97 Jimplementation schedule. -

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e find the licensee.'s approach to identifying equipment within the scope of paragraph (b)(3) of 10 CFR 50.49 acceptable since it is in accordance with the requirements of that paragraph.

Justification for Contf ,

ed Oceration

'The licensee has provided, in its February 22, and March 15 1985 submittals, justification for continued operation addressing each item or equipment for which the environmental cualification is not yet completed (see enclosure for the JC0 equipment list).

We have reviewed each JC0 provided by the licensee in its February 22, and March 15, 1985 submittals and find them acceptable since they are based on essentially the same criteria that were used by the staf# and its contractor te review JCO's previously submitted by licensees. These criteria, listed teicw, are also essentially the same as those contained in 10 CFR 50.49(i).

a. The safety function can be accomplished by sete other designated ecuipment that is qualified, and failure of the principal equipment as a result of the harsh environment will not degrade other safety functions or mislead the operator.

b. Partial test data that does not demonstrate full qualification, but provides a basis for concluding the equipment will perform its function.

If it can not be concluded from the available data that the equipment will not fail after completion of its safety function, then that failure must rot result in significant degradation of any safety function or provide misleading information to the cperator.

c. Limited use of administrative controls over equipment that has not been demonstrated to be fully qualified. For any equipment assumed to fail as a result of the accident environment, that failure must not result in significant degradation of any safety function or provide misleading information to the operator.

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9 C0llCLUSIONS -

Based on the above evaluation, we conclude the'following with regard to the

. qualification of electric equipment important to safety within the secpe of 10 CFR 50.49. .

• J -GPU's Oyster Creek electrical equipment environmental qualification

" ' program complies with the requirements of 10 CFR 50.49.

The proposed resolutions for each of the environmental qualificaticn

-deficiencies identified in the November 30, 1982 SER and FRC TER are

,'  : acceptable.

i LContinued:cperation until completion of the licensee's environmental .

cualification program will not present undue risk to the public health and' safety.

~ ACKNOWLEDGMENT lThis Safety Evaluation was. prepared.by P. Shemanski.

Dated: -May 28, 1985.

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1 10 Justification for' Continued Operation Equipment List Ovster Creek 10 Nc. NRC TER No. Description IG-CEA, OSB 42 GE/MAC Level Transmitters V-14-1,;5, 19, 20- N/A . Micro-Switch Limit Switches' IA-83A, B, C,'D,-E 49- Dresser Barksdale Pressure Switches / Controllers-

-RV-26A, B 43 GE/MAC Flow Transmitters RV-29A, B, C, D 51 Mercoid Pressure Switches V0-20 3,.4, 32, 33 N/A Limitorcue Motor Operator Limit Switches V0-20-92, 93, 94, 95 N/A NAMCO Limit Switches'

-IP-03A, B 44, 45 GE Flow Transmitters IP-ISA, 8 N/A .Ashcroft Temperature SwitcFes V-21-1, 3, 7, 9 6 Limitorque Motor Operator Limit Switches

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11 0PS-66A, B N/A ITT Barton Differential Pressure Switches RE-04A, B, C,,D 50 -

Static 0-ring. Pressure Switchs

-TE 109A, B,.C, D. N/A Pyco Temperature Elements o

TIP Ball. Valves N/A .

=G/E Solenoid Valves V-5-147, 167 14 Limitorque Motor Operators V-17'-55, 56, 57 5 Limitorque Motor Operator Limit Switches V-23-13, 14,-15, 16~ N/A Micro Switch Limit Switches V-23-17,.18, 21, 22- N/A'. NAMCO Limit Switches

V-27-1,2 _ N/A Micro Switch Limit Switches LV 3, 4 N/A NAMCO Limit Switches

.V-28-17, 18, a7 N/A. NAMC0 Limit Switches

-V-31-2. N/A: NAMC0 Limit Switches V-1-106, 107 12 Linitorque Motor Operator Limit Switches-V-1-110, 111 N/A- L'imitorque Motor Operator Limit Switches

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. V-~11-34 36. N/A Fischer Governor Co.

Limit Switches IA-90A, B .N/A Rosemount Differential

-91A, B. ,

Pressure Transmitters

-92A,-B-ID-13A, B 41 GE Level Transmitters

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ID.46.*, B 38 GE/MACPressureIndicatiig

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Transmitters RE-023, C, D 62 Yarway Level. Indicating Switches RE-05A, B 61, 63 Yarway Level Indicating

-19A, B- Switches

'TE-57-2A: N/A Hy-Cal' Temperature Elements 28 ..

MS-VE-l'.thru 21 N/A Endevco-Accelerometers /

-VX-1:thru:21. Coaxial" Cable Uholtz-TB-NR-28A Dickie Line Driver thru H, J TRW-Cinch Terminal Blocks 3, P, R' TB-NR-108A

~t hru E SS N/A GE CPM Selector Switch 6K-37X, 46X. N/A 'Agastat Relays 1A,' B N/A GE Non-Emergency Switchgear

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O, 13 1C, D- N/A GE Emergency Switchgear USS-1Al-011B_ N/A GE Static Time Delay Units

-1B1-021B.

1A1, 1B1- N/A- .GE Substation 460V Units MCC-1A-11,112. N/A GE 460V. Motor Control: Centers -

-21A, 21B; (73 for 21B),

-1B-13 MCC-1AB2,- 74 GE 460V Motor Control Centers

-L-1821A, 15215 MCC-DCl- 73 GE 125VDC Motor Control Center MCC-DC2' 75 ITE Gould 125VDC Motor Cor. trol Center

-Power Cable 80 Rockbestos'EP Cable Control Cable N/A Rockbestos Firewall III Cable

-Penetrations 72 GE Penetrations V-28-9 thru 16' N/A NAMCO Limit Switches

.V-28-21, 22_ N/A NAMCO Limit Switches

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