ML20138A248
| ML20138A248 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/27/1985 |
| From: | Massin H COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 0695K, 695K, GL-85-15, NUDOCS 8510080490 | |
| Download: ML20138A248 (7) | |
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Commonwealth Edison 7-one First National Plaza, ChrCago. Illinois O
Address Reply to: Post Office Box 767 Chicago, litinois 60690 September 27, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Units 1 and 2 Environmental Qualification of Electrical Equipment NRC Docket Nos. 50-373 and 50-374 References (a): Letters from J. G. Marshall to H. R. Denton dated January 1, January 30, February 5, February 22, and March 27, 1985.
(b): Letter from A. Schwencer to D.L. Farrar dated March 28, 1985.
(c): Letter from H.R. Denton to D.L. Farrar dated March 29, 1985.
(d): Generic Letter 85-15
Dear Mr. Denton:
The correspondence identified above as Reference (a) documented our request for extension on the schedular requirements of 10 CFR 50.49 for a limited number of items. This extension expires November 30, 1985 or first unit start-up thereafter. References (b) and (c) provided the NRC's approval of this request for Units 2 and 1, respectively.
More recently, the NRC has issued Reference (d) which discusses extensions required bcyond November 30, 1985. This generic letter states in part that any such requests received beyond September 30, 1985 will be considered untimely. Although no such need for an extension is anticipated for either Unit 1 or Unit 2, we wish to apprise the NRC of certain test activities which are still in progress. Because of the nature of testing, it is possible that at a point in time beyond September 30, 1985, the need to request an extension may become evident. The piece of equipment in question is the Klockner-Moeller Motor Control Center. More detailed information is provided in the attached report as to the status of testing and evaluation of results.
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H. R. Denton September 27, 1985 Because it is not possible at this time to determine conclusively whether or not further extension is required, we would request the NRC's cooperation in evaluating this matter even beyond September 30, 1985, if necessary. Please be advised that we recognize the need for notification as promptly as possible and we hereby commit to inform the NRC by November 15, 1985 if an extension beyond November 30, 1985 is required.
As a second matter, recall that the Comsip, Inc. Hydrogen-Oxygen Analyzer had been included in our initial request for extension, Reference (a). As detailed more fully in the attached report, a reevaluation of the function of this equipment has led us to conclude that it is not in the scope of 10CFR50.49 and need not be qualified on this time schedule. This letter therefore represents our notification to the NRC that the previously identified modification work will not be completed by November 30, 1985 but will be installed later as manpower and scheduling permit.
Please direct any questions you may have concerning this matter to this office.
One signed original and ten (10) copies of this transmittal and its attachments are provided for your use.
Very truly yours, p ]L. Massin h
H.
Nuclear Licensing Administrator 1m Attachment cc: Dr. A. Bournia - NRR Resident Inspector - LCSC 0695K
ATTACHMENT Klockner-Moeller Motor Control Centers Applications: 1&2AP71E; 1&2AP75E; 1&2AP76E; 1&2AP78E; 1&2AP82E; 1&2AP83E OBJECTIVE - Provide a status of test activities, preliminary evaluation of results, and schedule for completion.
DISCUSSION - The qualification of the MCC involves the testing of various items (forty-four sub-parts) including: motor starters, control and overload relays, contactors, and transformers. Testing is done both at the individual component level and at the circuit level.
The test sequence includes the following:
Heat-Rise Verification Test Baseline Functional Test Radiation Test Functional Test Thermal Aging Cycle Aging Functional Test Accident Test Functional Test At present, the post-accident functional test is nearing completion. All testing is being done at Wyle Laboratories or their designee.
Several test anomalies have been encountered and resolved during the execution of this test series. At present, investigation and resolution activities are still in progress for the following matters:
1) circuit breaker trip times which deviated slightly from the vendor's characteristic trip time curves.
11) a possible temperature / qualification-related effect on the tripping characteristics of ITE single pole circuit breakers.
iii) a voltage-related effect on the tripping characteristics of overload relays used in circuits for non-reversing loads (pumps, fans, heaters, etc).
iv) continued testing on a contactor; similar models failed previously dJring testing presumably due to excessively high thermal aging temperatures (a test induced failure).
S With the exception of the above activities and assuming satisfactory completion of the remaining functional test, it is our belief that all other items have demonstrated qualification with a qualified life not less than six years. Note that this belief comes from our close working relationship with Wyle during this test series; formal test data has not yet been submitted. A qualification conclusion will be formally documented prior to November 30, 1985.
Successful resolution of the above activites would result in fully qualified MCC components with qualified lifetimes which would not expire until the second refueling outage. Although the test simulates the as-installed configurations, it is possible that MCC setting alterations or limited part
- 6 replacements may be required in order to resolve the previously identified test anomalies. It is our intention to complete these activities as quickly as possible.
Should some of the above activies indicate that a qualification discrepancy exists, a review of individual circuits would be completed to more accurately assess the impact. It should be acknowledged that because the majority of MCC components have successfully completed qualification, the effect of any open items would be limited and would not render the entire MCC unqualified. Once open items are more specifically identified, the extent of impact will be quantified.
CONCLUSION - It.is our present intention to complete the identified
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activities as quickly as possible. Further, it is our belief that these matters can be satisfactorily resolved such that full qualification can be established prior to November 30, 1985. A possibility does exist, however, that qualification discrepancies may be discovered. At that time, the extent of the impact of such discrepancies will be evaluated. A request for an extension beyond the present qualification deadline of November 30, 1985, if required, will be submitted to the NRC not later than November 15, 1985.
0695K i
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. Comsip, Inc. Hydrogen - Oxygen Analyzer Panels Applications: 1&2PL76J; 1&2PL77J OBJECTIVE - To document the analysis for concluding that the subject equipment is not within the scope of 10 CFR 50.49.
DISCUSSION - The scope of equipment subject to the EQ rule is provided in 10 CFR 50.49b, subparagraphs (1), (2), and (3). These categories will be summarized below and reviewed individually for applicability to the subject equipment.
Category 1 - Safety-related equipment that is relied upon to remain functional during and following design basis events to ensure (1) the integrity of the reactor coolant pressure boundary, (ii) the capability to shutdown the reactor and maintain it in a safe condition, and (iii) the capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposures comparable to 10 CFR Part 100 guidelines.
Evaluation - The analyzers have been treated as safety-related equipment however, they perform no active function to ensure completion of the above safety objectives.
The analyzers are normally operated in the stand-by mode. Upon receiving an isolation signal, the analyzers are automatically initiated with on-line readings of hydrogen and oxygen concentration available following a 30-minute warm-up period.
The analyzers provide continuous indication in the control room via strip chart recorders and anm,:iate an alarm at predefined con.entration levels. The anei gt s cb not have logic or interlock functions and tMP n o not affect the automatic operation of any piece of a Qt required to ensure accomplishment of the three safet.y objectives identified.
Because of the function of the analyzers as providing display information only and not actively accomplishing an action to mitigate the consequences of a design basis event, it may be concluded that this equipment is not within the scope of 10 CFR 50.49(b)(1).
Category 2 - Non-safety related electrical equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions by safety-related equipment.
Evaluation - The analyzers are safety-grade equipment which are electrically separated from other safety related equipment. Their failure electrically via a short circuit would be isolated from the safety-related power supply by protective devices. Failure
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. mechanically by being incapable of drawing a containment atmospheric sample or to process it properly would only affect the quality and/or presence of the control room indication.
The effect of such a co.idition on operator action is evaluated under the next category. A mechanical fai. lure would have no effect on other safety-related equipment.
Because either an electrical or mechanical failure in the analyzers will not adversely effect the operation of other safety related equipment, it may be concluoed that this equipment is not within the scope of 10 CFR 50.49(b)(2).
Category 3 - Certain post-accident monitoring equipment.
Evaluation - The concern for equipment in this category is the inaccuracy /
inconsistency of control room indication which may mislead the operator.
The original intent of the analyzers was to provide on-line containment atmospheric monitoring such that at predefined levels of hydrogen or oxygen concentration, the hydrogen recombiner would be manually initiated by the operator.
Because the reliability of the analyzers was in question, procedural cautions were implemented to advise the operator to start the recombiners six hours into a core damaging event regardless of the control room indication (reference LOA-HG-01, Rev. 0). This time period was derived from analysis in Chapter 6 of the FSAR for hydrogen generation. This procedure effectively removes the output from the analyzers from the operator's decision making process such that the potential to mislead him is eliminated. Note that the hydrogen recombiners, which do actively accomplish a safety function to mitigate the consequences of a design basis event, will be fully qualified prior to any unit operation beyond November 30, 1985.
Because the analyzers do not have the potential to mislead the operator, it may be concluded that this equipment is not within the scope of 10 CFR 50.49(b)(3).
CONCLUSION - The Comsip, Inc. Hydrogen Oxygen Analyzers are not within the scope of 10CFR50.49 as defined by subparagraphs (b)(1), (b)(2),
and (b)(3). Accordingly, plant modifications required to up-grade this equipment to a qualifed status need not be implemented by November 30, 1985.
. Although our review of Reg. Guide 1.97 is not fully completed, this equipment was originally classified Category I monitoring a Type A variable and therefore required qualification for post-accident operation. Because the display from this equipment does not form the basis of operator decision-making and because the potential to mislead him has been eliminated through procedural means, it is our present position that this equipment as Category III and monitors a Type D variable:
The analyzer provides only back-up indication to verify proper operation of the hydrogen recombiner. When used in this manner, qualification is not required. A final evaluation on this subject will be completed by August 1986.
0695K
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