ML20205S234

Summary of 860502 Meeting W/Util & Inel in Bethesda,Md Re Equipment Qualification Program Problem Areas.Attendees List & Supporting Documentation Encl

ML20205S234
Person / Time
Site:	Fort Saint Vrain
Issue date:	06/01/1986
From:	Hinson C Office of Nuclear Reactor Regulation
To:	Lynch O Office of Nuclear Reactor Regulation
Shared Package
ML20205S237	List: ML20205S234 ML20205S259
References
TAC-42527, NUDOCS 8606120104
Download: ML20205S234 (18)

Text

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/,j WASHINGTON, D. C. 20555 fa N .m....t J Docket No. 50-267 JUN I 7986 MEMORANDUM FOR: Oliver D. T. Lynch, Jr., Section Leader Standardization & Special Projects Directorate Division of PWR Licensing-B FROM: Charles S. Hinson, Project Manager Standardization & Special Projects Directorate -

Division of PWR Licensing-B

SUMMARY

OF MEETING WITH PUBLIC SERVICE COMPANY OF COLORADO (PSC) IN BETHESDA TO DISCUSS PROBLEM AREAS OF THE FORT ST.

VRAIN (FSV) EQUIPMENT OVALIFICATION (EQ) PROGRAM, MAY 2, 1986 On May 2,1986, the NRC staff met with representatives of PSC in Bethesda, Maryland, to discuss five identified problem areas which must be resolved before FSV's equipment qualification program can be found acceptable by the staff. These five areas are; 1) exemption of FSV design basis accident (DBA) electrical equipment from 10 CFR Part 50.49, 2) EQ submittal package,

3) EQ of cables, 4) maintenance history review, and 5) Steam Line Rupture Detection and Isolation System (SLRDIS) review.

Attendees at the meeting are listed in Enclosure A.

DBA Electrical Equipment Exemption PSC asked the staff about the necessity of requesting an exemption to the environmental qualification requirements of 10 CFR Part 50.49 for FSV electrical equipment used to mitigate the consequences of a DBA 1 and 2, but that is not exposed to a harsh environment during these accidents. This equipment may be exposed to the harsh environment created by a High Energy Line Break (HELB), but it is not relied upon to mitigate the consequences of a HELB.

The staff stated that if equipment used to mitigate a DBA 1 and 2 is not exposed to a harsh environment during these accidents, then it doesn't have to be environmentally qualified for those harsh environments. Therefore PSC does not need an exemption to the requirements of 10 CFR Part 50.49. The staff requested that PSC submit a letter stating why the subject electrical equipment will not be exposed to a harsh environment during a DBA 1 and 2.

The staff will review all equipment used to mitigate a DBA 1 and 2 during the review of the overall EQ program. The staff's safety evaluation will then address this issue. The staff stated that PSC's position on this question was acceptable.

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4 EQ Submittal Package PSC submitted a Master Equipment List (MEL) for FSV as well as a description of the methodology used to create this list and PSC's compliance with 10 CFR Part 50.49 (b)(1), (b)(2), and (b)(3) (Enclosure B).

The MEL contains a listing of all EQ Safe Shutdown Equipment, subcomponents, and supporting systems located in areas potentially subject to harsh environments.

PSC has grouped this equipment into 50 separate "EQ binders". This grouping is not indicated in the MEL.

The staff requested that PSC submit a key list that identifies the items in each "E0 binder". The staff will review the MEL prior to the upcoming office of Inspection and Enforcement (IE) EQ audit and provide PSC with results of this review.

Equipment Qualification of Cables In order to qualify cables at FSV to comply with 10 CFR Part 50.49, PSC must identify the cable manufacturers / materials, physically inspect the cables, review the cable purchase orders, and institute a cable sampling program. PSC has divided the cables at FSV into three categories, based upon the amount of data that are available for each cable. Class I cables include those cables for which the manufacturer and material are known and a cable test report is available. Class 2 cables include those for which only the manufacturer and material are known. Only the material is known for Class 3 cables.

Seventy-five percent of the cables (broken into 23 cable files) at FSV are in Classes 2 and 3. PSC will make one file from each cable class available for NRC review by the end of May.

The staff will have to review these three cable packages before they can make any kind of juderment on the acceptability of PSC's cable qualification program. The staff stated, however, that FSV's cable qualification program should be based on test data, and not just on a paperwork analysis, as PSC has apparently done.

Maintenance History Review PSC described the progress being made on their three-phase maintenance history review program (Enclosure C). This program involves reviewing the adequacy of maintenance records for all equipment on the EQ MEL and determining the potential impact of this maintenance on the EQ status of this equipment. PSC has already completed the first two phases of this program and has begun work on phase three. PSC said that less than one percent of the items on the MEL were identified by this review and these items will be replaced / corrected during the upcoming outage.

The staff stated that they were satisfied with the direction PSC is taking in documenting their maintenance records. The staff will provide their evaluation of PSC's maintenance history review during the upcoming IE inspection.

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h/ June 1, 1986 SLRDIS Review PSC briefly described the function and location of SLRDIS at FSV and then '

responded to the ten review questions (Enclosure D) proposed by NRC reviewer Norm Wagner. PSC will respond in writing to these review questions within a week after formal receipt of these questions from the NRC.

PSC has installed the first of two SLRDIS panels in the FSV control room and will receive the second panel for installation in early June. The NRC must complete the Safety Evaluation Report of SLRDIS before PSC can finally wire SLRDIS into the plant. l Enclosure E is a copy of the meeting summary for the March 26, 1986 meeting at FSV on the Equipment Qualification Program. This meeting summary is encicsed for completeness.

Orig"' nal signed by Char es S. Rinson, Project Manager Standardization & Special Projects Directorate Division of PWR Licensing-B

Enclosures:

A. Attendance list B. FSV Draft EQ Submittal and MEL C. Maintenance History Review D. Staff questions on SLRDIS E. Meeting Summary of 3/26/86 Meeting'at FSV cc w/ enclosures-See next page DISTRIBUTION:

Docket File NRC PDR Local PDR SSPD Reading HBerkow PNoonan Olynch KHeitner CHinson OELD EJordan BGrimes ACRS (10)

NRC Participants cc: Licensee and Plant Service List

- :SSPD DPWR . SPD HH DPWRL-B:SSPD PR :SSPD an chi 'ac KHeitner 0 86 05hg /86 05/3c/86 0& d /86

SLRDIS Review PSC briefly described the function and location of SLRDIS at FSV and then responded to the ten review questions (Enclosure D) proposed by NRC reviewer Norm Wagner. PSC will respond in writing to these review questions within a week after formal receipt of these questions from the NRC.

PSC has installed the first of two SLRDIS panels in the FSV control room and will receive the second panel for installation in early June. The NRC must complete the Safety Evaluation Report of SLRDIS before PSC car finally wire SLRDIS into the plant.

Enclosure E is a copy of the meeting summary for the March 26, 1986 meeting at FSV on the Equipment Qualification Program. This meeting summary is enclosed for completeness.

. Md Charles S. Hinson, Project Manager Standardization & Special Projects Directorate Division of PWR Licensing-B

Enclosures:

A. Attendance list

8. FSV Draft EQ Submittal and MEL C. Maintenance History Review D. Staff questions on SLRDIS E. Meeting Summary of 3/26/86 Meeting at FSV cc w/ enclosures:

See next page

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Mr. R. F. Walker Public Service Company of Colorado Fort St. Vrain cc:

Mr. D. W. Warembourg, Manager Albert J. Hazle, Director Nuclear Engineering Division Radiation Control Division Public Service Company Department of Health of Colorado 4210 East lith Avenue P. O. Box 840 Denver, Colorado 80220 Denver, Colorado 80201 Mr. David Alberstein, 14/159A Mr. J. W. Gahm, Manager GA Technologies, Inc. Nuclear Production Division Post Office Box 85608 Public Service Company of Colorado San Diego, California 92138 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Mr. H. L. Brey, Manager Nuclear Licensing and Fuel Division Mr. L. W. Singleton, Manager Public Service Company of Colorado Quality Assurance Division P. O. Box 840 Fort St. Vrain Nuclear Station Denver, Colorado 80201 16805 Weld County Road 19-1/2 Platteville, Colorado 80651 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. 0. Box 640 Platteville, Colorado 80651 Kelley, Stansfield & 0'Donnell Public Service Company Building Room 900 550 15th Street Denver, Colorado 80202 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Chairman, Board of County Commissioners of Weld County, Colorado Greeley, Colorado 80631 Regional Representative Radiation Programs Environmental Protection Agency 1800 Lincoln Street Denver, Colorado 80203 8

s Enclosure A May 2, 1986 Meeting NRC - PSC 1

Attendees Organization Ken Heitner NRC/DRR/SSPD H. L. Brey PSC James Selan PSC George Hubbard NRC/VPB Allen R. Johnson NRC/RIV Mike Annon Proto-Power /PSC M. E. Niehoff PSC Paul Shemanski NRC/NRR/PWR-B/PEICSB John M. Fehringer INEL Charles Hinson NRC/NRR/SSPD Sam Marquez PSC Dan Brown PSC Jeff Johns- PSC W. Shields NRC/0 ELD N. Wagner NRC/PEICSB I

s 2420 W. 26th Avenue, Suite 1000, Denver,. Colorado 80211 "6'###'

April , 1986 Fort St. Vrain Unit No. 1 P-86 Dir.ector of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Mr. H. N. Berkow, Director Standardization and Special Projects Directorate Docket No. 50-267

SUBJECT:

Fort St. Vrain Draf t E.Q. Submittal

REFERENCES:

1) NRC letter, Berkow to Walker, dated 2.-14-86 (G-86086)

2) PSC letter Walker to Berkow dated (P-86280)

Dear Mr. Berkow:

The purpose of this letter is to provide the NRC Staff with an Environmental Qualification (EQ) submittal. The need for this submittal was originally discussed with the NRC Staff during the February 21, 1986 Environmental Qualification meeting at Fort St.

Vrain. Later clarification to the necessary submittal content was obtained during an April 16, 1986 conference phone call with fir. Ken Heitner of the NRC Staff.

The objective of the submittal is to summarize Public Service Company's (PSC's) ongoing activities that will assure our compliance with 10CFR50.49. The detailed evaluations and other information required to substantiate PSC's compliance will be available for NRC review prior to our request for release to go to full power at Fort St. Vrain.

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. P-86 April , 1986 The submittal is formatted in the following manner:

Part 1 -

Methodology for creation of the Fort St. Vrain Master Equipment List (MEL) and compliance with 10CFR50.49 bl, b2 &

b3.

Part 2 - Summary of the Fort St. Vrain EQ Program considerations as they relate to compliance with 10CFR50.49.

Part 3 -

Summary of Fort St. Vrain's activities to assure continued compliance with 10CFR50.49.

Part 4 - Summary of various EQ subjects currently being discussed with the NRC Staff.

If you have any questions regarding this submittal please contact -

Mr. M.H. Holmes at (303) 480-6960.

Very truly yours, D.W. Warembourg, Manager Nuclear Engineering Division DWW/ MEN:pa Attachments

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s /z/et. 9 (s) 6aclosure C-MAINTENANCE HISTORY REVIEW OBJECTIVE: TO IDENTIFY THOSE ITEMS WHICH ARE NOT IDENTICAL TO THE AS-PROCURED STATE.

SCOPE: REVIEW 0F SSR/PTR'S INITIATED PRIOR TO OCTOBER 1, 1985.

APPROACH: 3 PHASE APPROACH PHASE I --SSR/PTR BULK REVIEW DEVELOP SSR/PTR MASTER LIST (EQ MEL ANNOTATED TO REFLECT COMPONENTS ALREADY BEING REPLACED OR MODIFIED).

PERFORM REVIEW IN REVERSE CHRONOLOGICAL ORDER.

COMPARE COMPONENT LISTED ON SSR/PTR TO SSR/PTR MASTER LIST.

RECORD APPLICABLE SSR/PTR'S AND COPY APPROPRIATE DOCUMENTS.

PHASE II - DETERMINE EQ IMPACT ASSEMBLE SSR'S/PTR'S COPIED INTO SYSTEM PACKAGES.

REVIEW & CATEGORIZE SSR'S/PTR'S COPIED AS FOLLOWS:

1. WORK EFFECTS EQ

2. WORK POTENTIALLY EFFECTS EQ

3. WORK DEFINITELY DOES NOT EFFECT EQ PHASE III - FINAL REPORT DOCUMENT RESULTS OF PHASES I & II.

PROVIDE SPECIFIC RECOMMENDATIONS FOR EACH ITEM THAT EFFECTS OR POTENTIALLY EFFECTS EQ.

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GENERAL GUIDELINES FOR REVIEW USE MOST CONSERVATIVE APPROACH IN DETERMINING IF WORK IMPACTS EQ.

REVIEW EXCLUDES THOSE ACTIVITIES COVERED BY SEPARATE DETAILED REVIEWS; I.E.

JUNCTION B0XES k ' ' ' i '

CABLE SPLICES NF u Ib di A" * / " */d-

CABLE (EXTERNAL TO COMPONENTS)

LIMIT SWITCH / TORQUE SWITCH SETTINGS TORQUING REQUIREMENTS LUBRICANTS i

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EQ RELATED COMPONENTS MOTOR MOTOR OPERATOR LIMIT SWITCH TORQUE SWITCH PRESSURE SWITCH TEMPERATURE SWITCH LEVEL SWITCH FLOW SWITCH CONTROL SWITCH SOLEN 0ID VALVE TRANSOUCER (XEP, SQUARE ROOT, ETC.)

INSTRUMENTS - TRANSMITTER CONTROLLER INDICATOR RELAY TRANSFORMER MCC - BREAKER, STARTER ELECTR0-HYDRAULIC SERVO ACTUATOR ELECTRO-PNEUMATIC POSITIONER THERMAL HOOD CONTROL VALVE g h, ,wpau c/;'l N n.s a .;.

e TASKS THAT IMPACT EQ ITEM WORKED IMPACT EQ DON'T IMPACT E0*

MOTOR REPLACE MOTOR PAINT MOTOR REWIND MOTOR REPLACE / REPAIR CABLE REPAIR INSULATION CLEAN MOTOR TRANSMITTER REPLACE / REPAIR PC BOARD CALIBRATION REPLACE / REPAIR COMPONENT CHANGE MANIFOLD SEALANT AT CONDUIT FITTING RETUBE LUBRICATE REPLACE / REPAIR VENT VENT VALVE CLEAN CHANGE RANGE MOTOR REPLACE / REPAIR ELECTRICAL REPLACE / REPAIR OPERATED ACCESSORIES MECHANICAL ACCESSORIES VALVE REPLACE VALVE REPACK VALVE LUBRICATE REPLACE TRIM CLEAN ADJUST LIMIT / TORQUE REPAIR / REPLACE LIMITORQUE SWITCH VENT VALVE

• FOR THE PURPOSE OF THIS REVIEW ONLY.

WORK SCOPE EFFECT ON EQUIPMENT QUALIFICATION

• POTENTIALLY NOT ITEM WORKED ** IMPACTED IMPACTED IMPACTED MOTOR REWIND MOTOR REPAIR INSULATION. THE REPLACEMENT REPLACEMENT MOTOR MOTOR MODEL WAS MODEL NUMBER NOT QUALIFIED.

KNOWN.

CLEAN MOTOR TRANSMITTER REPLACE PC SEALANT BOARD.

REPLACE THERMAL HOOD COMPONENT ON WTot. BOARD.

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VALVE LUBRICATE CLEAN FOR THE PURPOSE OF THIS REVIEW ONLY.

• • EXAMPLE ONLY, NOT ALL INCLUSIVE.

REVIEW APPROACH (PHASEI)

STEP A: THE MASTER EQUIPMENT LIST (M.E.L.) WAS REDUCED TO ELIMINATE ALL ELECTRICAL COMPONENTS ADDRESSED ON AT-RISK MEMOS, AND COMP 0NENTS REPLACED OR REMOVED BY PSC CN (CHANGE NOTICE).

STEP B: THE M.E.L. WAS FURTHER REDUCED BY ELIMINATING GENERIC

, COMPONENTS COVERED BY SEPARATE REVIEW EFFORTS.

STEP C: STATION SERVICE REPORTS (SSR) AND PLANT TROUBLE REPORTS (PTR) WERE REVIEWED TO DETERMINE IF THE DESCRIBED EQUIPMENT WAS ASSOCIATED TO THE REDUCED M.E.L.

STEP 0: THE ASSOCIATED SSR/PTRS WERE THEN COPIED AND THE ORIGINAL DOCUMENTS RETURNED TO RECORDS STORAGE.

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(PHASE II)

STEP E: THE COPIED SSR/PTRS WERE THEN EVALUATED TO DETERMINE IF THE WORK DESCRIBED COULD EFFECT THE E.Q.

QUALIFICATION OF EACH M.E.L. COMPONENT (REPORT FORM).

STEP F: WORK DESCRIPTIONS WERE THEN IDENTIFIED FOR REPLACEMENT, COMPLETE COMPONENT REPLACEMENT FURTHER WORK HISTORY RESEARCH.

STEP G: ANY ITEM WITH A POTENTIAL E.Q. IMPACT WAS THEN EVALUATED AND GROUPED INTO INDIVIDUAL PACKAGES.

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PHASE III STEP H: THOSE COMPONENTS DETERMINED TO BE OF QUESTIONABLE IMPACT WERE THEN SUBJECTED TO A MORE DETAILED EVALUATION AND GROUPED INTO ONE OF THE FOLLOWING CATEGORIES:

NO EQ IMPACT HAS POTENTIAL EQ IMPACT BECAUSE (1) PARTS USED REQUIRE RESEARCH (2) NO PARTS TRACEABILITY (3) INADEQUATE WORK DESCRIPTION (4) TOTAL COMPONENT REPLACED (5) COMPONENT REPLACED WITH REBUILT UNIT STEP I: PERFORMED FOLLOW-UP RESEARCH INTO POTENTIAL EQ IMPACT ITEMS.

STEP J: MADE SPECIFIC' RECOMMENDATIONS FOR EACH ITEM WITH POTENTIAL EQ IMPACT.

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FORT ST. VRAIN REQUEST FOR ADDITIONAL INFORMATION EQUIPMENT QUALIFICATION (SLRDIS)

1. Since a high energy line break will result in a defined jet of hot water or steam in a limited area, justify your assumption that the entire length of thermistor cable in the steam line rupture detection and isolation system (SLRDIS) will be at the same temperature after a high energy line break. Further, because the entire length of a 200 ft, long thermistor cable must "see" a 55 F/ minute temperature change following a high energy line break in order to initiate a secondary system isolation signal, show that the SLRDIS response time to this condition is rapid enough to result in the required isolation prior to exceeding equipment qualification envelopes for essential plant shutdown equipment.

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2. Discuss your plans to verify continued satisfactory operation of the SLRDIS after initial installation including your proposal to conduct periodic systematic tests of the SLRDIS in place. This discussion should include the technical specification modifications you plan to provide to accomplish periodic, in situ testing. Discuss how you intend to verify the SLRDIS response time assumed in the safety analyses.

l 3. Discuss actions to be taken by plant operators in the event the pre-trip alarm temperature (135"F) is reached following a high energy line break i (HELB) without causing the 55*F/ min. temperature change that would result in automatic SLRDIS actuation. Show that equipment needed for plant shutdown in such an event is not damaged by the HELB.

4 Provide the following information for our review (as noted in Attachment 1 to your letter P-86208, dated March 14,1986):

a. Resistance vs Temperature curve of the 9090-13 thermistor cable (200' lengths used at Fort St. Vrain) Dwg. No. 280023 Rev. A;

b. Sensor Center Conductor to Case Resistance vs Temperature - Initial and Final Curves after Accelerated Aging and Radiation Tests;

c. Functional Test of Alison Control After Seismic Test - dated 11/1985;

d. Equipment Qualification Package;

e. Seismic Test of Control Rack and Sensor Assemblies performed by Wyle Labs, 11/9/85;

f. Response Time Test of Thermistor Cable performed by Factor Mutual Research Corporation, 12/10/85; and

g. Qualification Test Report of 9090-13 Sensor Assembly (Doc. No.

ETR101), dated 2/7/84 for Application at Davis-Besse.

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5. Provide a discussion which indicates how the unavailability goal of 0.01 has been attained for the portions of the SLRDIS shown in Figure 3 of Attachment 2 to your letter P-86208. If this discussion is not for the complete SLRDIS, indicate what the unavailability is for the entire SLRDIS.

6. Confirm that in the event of a fire in those areas which may impact on the SLRDIS, safe shutdown of the plant is not affected.

7. Attachment 2 (Page 4.4-6c, action statement 1) to your submittal dated 12/31/85 (P-85456) discussing the SLRDIS system states:

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Power operation above 8% rated thermal power may continue provided the inoperable channel is placed in the bypassed or tripped condition--- ".

Provide justification for placing an inoperable channel in the -

bypassed condition.

8. Will a high energy line break in some areas cause increased temperatures in both the reactor building and turbine building? If so, show that you have accounted for this in the qualification of essential equipment.

9. I; there a potential for a steam line break at power levels $iS9% to be m)re severe than those at higher power levels because of the use of auxiliary boilers? If so, show that your analyses confirming equipment qualification has accounted for this potential.

10. S'10w that essential equipment required for shutdown, including instrumen-tition, exposed to spray from moderate energy line breaks is qualified to withstand such spray and maintain their function.

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