ML20209C779
| ML20209C779 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/14/1984 |
| From: | Noonan V Office of Nuclear Reactor Regulation |
| To: | Parr O Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17083B484 | List:
|
| References | |
| FOIA-86-197 NUDOCS 8403280330 | |
| Download: ML20209C779 (19) | |
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- fr.s. Recoq'o e-UNITED STATES
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WASHINGTON, D. C. 20555 g((
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MAR 14 1984 MEMORANDUM FOR:
Olan D. Parr, Chief Auxiliary Systems Branch Division of Systems Integration FROM:
Vincent S. Noonan, Chief Equipment Qualification Branch Division of Engineering
SUBJECT:
DIABLO CANYON UNIT 1 SSER 20, FOLLOWUP ITEM 5
Reference:
PG and E Letter No: DCL-84
, J. O. Schuyler to G. W.
Knighton dated January 20, 1984, " DRAFT".
During an environmental qualification audit of Diablo Canyon electrical equipment, conducted August 21 to September 4, 1981, the staff identified a motor capacitor in an Electro-Hydraulic Actuator, manufactured by ITT General Controls, as an item of concern because of insufficient docu-mentation to support aging qualification.
This is the same item identi-fied in SSER 20 as followup Item 5.
The applicant has submitted several documents to support its claim of qualification.
However based on our review of that documentation, the Equipment Qualification Branch has not been able to conclude that this equipment has been demonstrated to be environmentally qualified for the postulated high energy line break environment.
In the attached referenced letter and notes for table 3.11-1A in amendment 69 of the Diablo Canyon FSAR, the applicant stated.that I
the actuators in question are not required to operate in a harsh I
environment since they are not needed to mitigate the consequences of a high energy line break.
The staff reviewed, and found acceptable, information supporting the applicant's determination that this equipment is not required to operate following a high energy line break.
The staff's evaluation, attached, is documented in SSER No. 9.
I We request that you reaffirm the staff's previous evaluation by reviewing the attachments to this memo, and determine whether or not the actuators in question are required to mitigate either the consequences of a high energy line break or a loss-of-coolant accident.
Please provide us with a written evaluation of your findings by March 23, 984.
/
'x onan, Chief quipme Qualification Branch Division of Engineering j
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See next page GS'OJ22033
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Olan D. Parr cc:
J. P. Knight L. Rubenstein T. Novak G. Knighton R. LaGrange J. Wermiel H. Scherling H. Walker 1
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A772CHHoJT~l DRAFT January 20, 1984 PGandE Letter No:
DCL '
Mr. George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing
)
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission 1
Washington, D. C.
20555 Re: Docket No. 50-275, OL-DPR-76 i
Diablo Canyor. Units 1 and 2 SSER 20 Followup Item 5 -Nesro.c
Dear Mr. Knighton:
As requested by the Staff, the enclosure to this letter provides a complete history and chronology of environmental qualification developments related to the motor / capacitor set used in the auxiliary feedwater level control valves for Units 1 and 2.
.- Kindly acknowledge receipt of this material on the enclosed copy of this letter'and return it in the~ enclosed addressed envelope.
Sincerely, J. O. Schuyler TNCrawford/GCW/JOS:naw Enclosure l
cc:
D. G. Eisenhut l
H. E. Schierling Service List bec:
Diablo Distribution i
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0045d/0002D
DRAFT PGandE Letter No. DCL-84-019 ENCLOSURE A HISTORY OF THE ELECTRD-HYDRAULIC ACTUATORS ON THE. AUXILIARY FEEDWATER CONTROL VALVES Original Design The auxiliary feedwater control val,ves were originally designed to have strictly manual control. They had air actuators and failed to the open i
position.
Steam generator level control was' included to mi.nimize operator involvement during plant startup. The level control was a nonsafety-related function of the valves.
During system design review, it was noted that runout protection was needed I
for the 500 hp pumps at low steam generator pressures. A safety-related l
pressure override control was added to the control loop to satisfy this requi rement.
System Changes Later design reviews (1974) showed that.on loss of offsite power, the air actuators could not provide runout protection; therefore, they were replaced with electro-hydraulic actuators.
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When the original high energy line break (HELR) analysis outside of containment was performed, an evaluation was conducted to demonstrate that the plant could be brought to a safe shutdown condition under HELB environmental conditions without the use of auxiliary feedwater level control valves.
The 0045d/0006K.
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basic argument was that the valves, when subject to the HELB harsh environment, would be feeding the faulted steam generator (in addition to one other steam generator), and the correct operator action to mitigate the break involved stopping the pump, thus negating the need for runout protection.
This scenario was discussed with the NRC Staff in meetings from July 31, 1978 to August 11, 1978. As a result of those meetings, Amendment 69 to the FSAR, dated September 1978, included a " Notes for Table 3.11-1 A" which resolved Staff concerns. These notes are included as Attachment 1.
In 1979, for reasons unrelated to this issue, PGandE replaced the original electro-hydraulic actuators with the ITT General Controls actuators.
In 1980, Memorandum and Order CLI-80-21 was issued by the NRC directing PGandE and other utilities to review the environmental qualification of all safety-related electrical equipment using NUREG-0588 as a guideline.
This directive was transmitted to PGandE in a letter from John F. Stolz to John C.
Morrissey dated March 3,1980.
PGandE approached this qualification effort using two approaches that impact the valves under discussion.
First, if PGandE could demonstrate that a device was qualified for a harsh
' environment, the qualification would be documented, whether or not that device was required to function in the harsh environment.
Equipment was 'only reviewed for justification of functional exemption if it could not be qualified.
Second, Diablo Canyon is a Category II plant as defined in NUREG-0588 and is only required to address the effects due to aging as opposed to aging quali fication.
PGandE decided to include qualification for aging in its program, as is required for Category I plants. The basis for this decision was the knowledge that most of the equipment could be qualified to these requirements.
Wyle Laboratories had a contract with PGandE to qualify the remainder of the equipment by using existing test data from other applications and correlating them to the Diablo Canyon equipment.
PGandE had been assured by Wyle that this program of aging qualification would be successful.
0045d/0006K - - _ _
DRAFT When the details of the various ITT General Controls environnertal qualification reports were evaluated for applicability to the Diablo Canyon actuators, PGandE discovered that the critical testing involved a three-phase motor and Diablo Canyon had a single-phase motor.
ITT informed PGandE that the only significant difference, from a qualifica, tion point of view, was that the single-phase motor had a capacitor and the three-phase motor did not.
ITT stated that the capacitor had been qualified for radiation by test and cited a report not in PGandE's possession.
ITT stated that the PGandE motor had the standard capacitor, as opposed to the high radiation resistant capacitor, but that the qualification test showed the standard capacitor was acceptable for Diablo Canyon's postulated radiation levels.
Lacking a copy of the report, PGandE allowed the qualification of the capacitor to remain an open item and provided a justification for interim operation in the September 1981 report to the NRC.
PGandE also stated that the thermal aging portion of the qualification would be included in the Wyl.e aging program.
In early 1982, the Wyle aging program was abandoned because the results could not be applied by PGandE to qualify the equipment for aging.
PGandE then investigated other alternatives.
For the actuators,.this included additional discussions with ITT. These discussions resulted in more qualification reports, including one which showed the qualification of an actuator with the single-phase motor.
(It sh'ould be understood that the capacitor is merely a" component of the single-phase motor design.
Consequently, most of the reports never mention a capacitor, but discuss only single-phase or three-phase motors.)
In mid-1982, while this qualification infonnation was being integrated into PGandE files, the IDVP chose to review the file for these actuators.
In accordance with the scope of the IDVP, PGandE provided copies of this file as it existed in November 1981.
The IDVP found the statement in the file that the capacitor was not qualified.
E0I 8058 was issued stating that the actuators were not qualified.
PGandE's response to the IDVP to resolve this E0I was that this issue was known to the NRC and the justification for interim 0045d/0006K -_
DRAFT operation had been reviewed and found to be adequate by the NRC.
The E01 was subsequently closed.
Separately, in response to EDI 8001, PGandE. reanalyzed the environment in the auxiliary building resulting from a high energy line break. The resulting peak temperature for the auxiliary feedwater control valves increased from 0
0 approximately 209 F to 325 F (See Attachments 2 and 3).
Since the ITT 0
General Controls actuator is only qualified for 212 F as indicated in, PGandE decided to provide an exemption for this actuator which had already been justified in FSAR Table 3.11-1A.
Although the environmental temperatures are changed, the justifications for exemption are still valid.
On December 20, 1983, the NRC Staff and its consultant, EG8G, audited the valve actua, tor files for the revised temperatures outside containment. The Diablo Canyon Project explained to the NRC representatives that the actuators would be documented in the qualification file to be exempt from the requirement to operate during an HELB, and they agreed that this was a legitimate approach to the qualification issue. The Project decided to
. consider this approach separately from the capacitor qualification issue so
'that the capacitor issue could be closed.
' Revision 2 of the qualification file for the actuator was issued on December 30, 1983, to reflect this positon.
(Revision 0 was the original file, and Revision 1 was the mid-1982 update to include qualification with the i
capacitor.)
This file is currently being maintained to document the qualification to post-LOCA radiation environments which PGandE has selected not' to exempt at this time. The valve actuators are now considered to be qualified for the environments in which they must operate as defined in NUREG-0588.
The followit.g infomation provides a brief chronology of the events related to environmental qualification of the auxiliary feedwater control valves.
0045d/0006K.
DRAFT July - August 1978 Meetings with NRC to justify exclusion from qualification.
September 1978 FfAR Amendment 69 to document exclusion from qualification March 3,1980 Letter from Stolz to Morrissey to meet NUREG-0588 requirements Spring,1980.
New ITT General Controls actuators installed September,1981 Final Environmental Qualification Report i.ssued - NRC audit of files; SSER 15 issued by NRC approving PGandE's EQ program November,1981 EQ documents provided to IDVP for review-Spring, 1982 Cancellation of Wyle program June,1982 Revision 1 of actuator File IH-14 issued October,1982 EDI 8058 issued - Environmental qualification of actuator March,1983 EDI 8058 c1'osed November 18, 1983 Design Criteria Memorandum M-73 issued - New temperature and pressure environments Early December,1983 Decision made to exempt actuators for HELB environment l
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0045d/0006K DRAl-1
' December 20, 1983 NRC auditor informed of decision to exempt actuator for HELB, but not post-LOCA environment December 22, 1983 PGandE letter to NRC or SSER 20 Followup Item 5 December 30, 1983 Revision 2 to File IH-14 issued exempting valve actuators from HELB environment December 30, 1983 Equipment deemed qualified for all environments in which it was required to operate.
O O
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0045d/0006K. _
DRAFT.
. to the Enclosure NOTES FOR TABLE 3.11-1A (Provided in Response to Informal Staff Request During July 31 - August 11, 1978 Meetings)
Justification for the Exclusien of the Auxiliary Feedwater Level Control Valves From the Severe Environment Exposure List Auxiliary feedwater is ' supplied to the steam generators by one turbine driven and two motor driven auxiliary feedwater pumps.
The turbine driven pump has sufficient capacity to supply emergency feedwater to four steam generators.
Each motor driven pump has sufficient capacity to supply emergency feedwater to two steam generators.
The turbine driven purnp isolation valves are manually positioned motor operated valves (MOV). The motor driven pump's steam generator level control valves are automatic, electro-hydraulically operated valves (E-H) with manual override.
Two turbine driven pt.mp level control valves.and the two E-H level control valves for one motor 6 riven pump are located in plant area F pipeway near the main steam and main feedwater containment penetrations for steam 69 generators 1 and 2.
The other two turbine driven pump level control valves
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and the two E-H 1evel control valves for the second motor driven pump are located in plant area GE, elevation 115'-0", near the. main steam and main feedwater containment penetrations for steam generators 3 and 4'.
Plant areas F and GE are diametrically opposite on the containment structure. Plant area F is outdoors and area GE is inside the Auxiliary Building.
If a. main steam line break were to occur in either plant area, two MOV isolation valves and two E-H control valves would be subjected to an environmental temperature that rises to a maximum of 212*F for 300 seconds and stabilizes at 200*F.
The MOV's are environmentally qualified and are shown on the severe environment list.
The E-N's have not been tested for this type of environment.
If this condition failure of the E-H actuators, the motor driven pump to these valves ould shut off.
Since they feed the steam generator which would be fee break, this is not only acceptable, it is desirable.
The MOV to the affected steam generator could be closed, and the turbine driven pump could supply the 3 unaffected steam generators.
As a backup, the motor driven pump to the unaffected E-H valves could supply the two unaffected steam generators on the other side.
Therefore, the auxiliary feedwater level control valves are not required to be qualified for a severe environment.
"181'" 2
' to the Enclosure' Nuclear Services Corporation DRAFT
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. ArrACHHY 2-NOTES FOR TABLE 3.11-1A (Provided in Response to Informal. Staff Request
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During July 31 - August 11, 1978 Meetings)
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Justification for the Exclusion of the Auxiliary Feedwater, Level Control Valves From the Severe. Environment Exposure List Auxiliary feedwater is supplied to the steam generators by one turbine driven and two motor driven auxiliary feedwater pumps.
The turbine driven pump has sufficient capacity to supply emergency feedwater to four steam generators.
Each motor driven pump has sufficient capacity to supply emergency feedwater to two steam generators.
The turbine driven pump isolation valves are manually positioned motor operated valves (MOV). The motor driven pump's steam generator level control valves are automatic, electro-hydraulically operated valves (E-H) with manual override.
Two turbine driven pump level control valves and the two E-H level control valves for one motor driven pump are 1ccated in plant area F pipeway near the main steain and main feedwater containment penetrations for steam 69 generators 1 and 2.
The other two turbine driven pump level control valves and the two E-H level control valves for the second motor driven pump are located in plant area GE, elevation 115'-0", near the main steam and main feedwater containment penetrations for steam generators 3 and 4.
Plant areas F and GE are diametrically opposite on the containment structure.
Plant area c
F is outdoors and area GE is inside the Auxiliary Building.
If a main steam line break were to occur in either plant area, two M0V isolation valves and two E-H control valves would be subjected to an environmental temperature that rises to a maximum of 212*F for 300 seconds and stabilizes at 200'F. 'The MOV's are environmentally qualified and are-shown on the severe environment list.
The E-H's have not been tested for l
this type of environment.
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If this condition caused a failure of the E-H' actuators, the motor driven pump to these ' valves could be shut off.
Since they feed the steam generator which would be feeding the break, this is not only acceptable, it is desirable.
The MOV to the affected steam generator could be closed, and the turbine driven pump could supply the 3 unaffected steam generators.
As a backup, the motor driven pump to the unaffected E-H valves could supply the two. unaffected steam generators on the other side.
Therefore, the auxilirry feedwater level control valves are not required to be qualified for a severe environment.
C Amendmerit 69 thotember 1978)
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J E 3.11-1A ENVIRONMENTAL QUALIFICATION Sheet I af 3 i
0F CLASS IETEQUIPMENT WITH POTENTIAL FOR EXPLOSURE TO A SEVERE ENVIR0lMENT_
Class IE Equipment inside Containment - Subject to LOCA Equipment Manufacturer Type,(Model No.)
Qualffication Citation l
1.
Pressure and Differential Transmitters Rosemount Report #117415 j
a.
Pressurizer Pressure
- Rosemount 1152 764 FSAR Paragraph 3.11.3-7 f
b.
Pressurtzer Level ITT Barton c.
Contalrment Sisap Level ITT Barton 764 FSAR Paragraph 3.11.3-7 d.
Reactor Coolant System ITT Barton 763 FSAR Paragraph 3.11.3-7 Wide Range Pressure 69 e.
Narrow Range Steam ITT Barton 764 FSAR Paragraph 3.11.3-7 Generator Level f.
Steam Flow
- Rosemount 1152 Rosemowit Report #117415 g.
Sensor for Containment Pressure Barton 351 PGandE Letter to NRC.
9-21-78.
2.
Resistance TemM rature Detector a.
Reactor Coolant System Sostman 118345-1 PGandE Letter to NRC.
9-21-78.
Temperature 3.
Valve Motor Operators Limitorque' SMB-0. 00. 000 FSAR Paragraph 3.11.3-7 4.
Containment Fan Cooler Westinghouse 300/100 h.p.
FSAR Paragraph 3.11.3 WCAP 7829 - Fan Cooler Motor Test PG&E letters to Nor 2-10-78 and 1/10/78 j
- Required for Initiation Only l
Amendment 69 (Septend>er 1978) e 8
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TABLE 3.11-1A Sheet 2 of 3 i
Equipment Manufacturer T m (Model No.)
Qualificatica citation 5.
Electrical Penetrations General Electric NS02/03/04 Record Numbers 663081-18, 19 & 20 FSAR Paragraph 3. I1.3-6 l
6.
Electrical Cables Continental Silicon / Silicon Continental Test Report CC-2193S F
(3/71)
Boston Silicon /Hypalon Record Number 663359-20 Raychem Stilan Raychem memo on LOCA Testing at Franklin Institute Labs (2/10/75) i Okonite Tefzel Record Number 663359-69 j
Boston Silicon Glass Briad/
PCTE Engineering Research Test Kapton/Hypalon Report LSS-1586 (3/5/71) i 7.
Electrical Terminations Raychem Scaled Splice Franklin Institute Report
- F-C 4033-3 (1/75)
FSAR Paragraph 3.11.3-5 1
8.
Stem Mounted Limit Switches Namco EA180 Acme Cleveland Report (3/3/78) 9.
Containment Isolation ASCO 8300' FSAR Paragraph 3.11.3-3 Solenoid Valves 8302 8316*
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C1cas IE Equipment Outside Containment - Subject to High energy Line Break 1.
Electrical Cables
.Raychem '
Flantrol Raychem Test Report EM 1030 (9/24/74)
Okonite EPR/Okolan (Hypalon)
Okonite Test Report (10/14/74) 2.
Feedwater Flow Sensors Fischer and Porter 10B2496PBBA 7410-L Main Steam Line Pressure Fischer and Porter 50EP1041BCX WCAP 7410-L l3.
4.
Aux. Feedwater Isolation Limitorque SMC-04 Valve Motor Operators
- Special valves with all plastic parts replaced with stainless steel or brass parts to withstand higher temperatures.
Amendment 84 (July 80)
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TIME UNITS I AND 2 DIABLO CANYON SITE FIGU.RE 3.11-1
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ENVIRONMENIAL CONDITIONS FOR EQUIPMENT TESTING - PRESSURE, AS A FUNCTION OF TIME
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f The following quotation is contained in Safety Evaluation Report, Supplement No. 9, dated June 13, 1980 (page 7-1).
" Environmental Qualification - Class IE Equipment Exposed to Severe Environments In SER Supplement 7 we required the applicant to furnish a listing of all BOP and NSSS safety-realted equipment that may be required to fu'nction under severe environmental conditions. This Ifst was to identify the equipment, its manufacturer, its model number, its location, and a specific reference to its qualification report. We
-reviewed FSAR Table 3.11-1A which lists this equipment and provides the requested information. We find this response acceptable."
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