ML20213E694
| ML20213E694 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/17/1983 |
| From: | Knight J Office of Nuclear Reactor Regulation |
| To: | Houston R Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-0679, CON-WNP-679 NUDOCS 8312070348 | |
| Download: ML20213E694 (2) | |
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DISTRIRLI.10fL CCentral Filed NOV ; 7 l963 EQB Reading File MEMORANDUM FOR:
Robert W. Houston, Assistant Director for Reactor Safety Division of Systems Integration Daniel Muller, Assistant Director for Radiation Protection Division of Systems Integration Lester Rubenstein, Assistant Director for Core and Plant Systems Division of Systems Integration FROM:
James P. Knight, Assistant Director Components & Structures Engineering Division of Engineering
SUBJECT:
JUSTIFICATIONS FOR INTERIM OPERATION, WASHINGTON NUCLEAR PROJECT 2 (DOCKET NO. 50-397)
The Equipment Qualification Branch, Division of Engineering has recently received from WPPSS justification for interim operation with safety-related electrical and mechanical equipment which will not be fully qualified for seismic and dynamic loadings.
Because these justifications are interdisciplinary and often require a detailed knowledge of the systems in which equipment functions, your assistance is requested for this review.
The DSI and DE cognizant review branches should be responsible for the following:
1.
Review of equipment functions within a system and failure consequences.
2.
Review of alternate equipment to accomplish the safety function. contains the individual justifications.
In the upper right hand margin of each page, the branch believed to be responsible for the review has been listed.
If another branch is responsible, please notify R. Wright (X28209).
Justifications have not been provided for all outstanding equipment since WPPSS anticipates obtainirg full qualification documentation for those items prior to fuel load.
Contact:
R. Wright, NRR F.xt.__26209 M
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' Your prompt attention is requested.
Written responses should be forwarded to us no later than November 22, 1983, in order that there be no impact on the licensing schedule.
James P. Knight, Assistant Director Components & Structures Engineering Division of Engineering Attachments:
As stated cc:
w/o attachments w/ attachments V. Noonan R. Wright
- 0. Parr T. Collins W. Gammill J. Ridgely F. Congel S. Rhow V. Benaroya R. Giardina A. Schwencer J. Singh, INEL E. Weinkam G. Bagchi R. Auluck t
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Washmgtan Public Powsr Supply Syst:m P.O. Box 968 3000 GeorgeWashington Way flichland, Washington 99352 (509)372-5000 U ( vJ November 4, 1983
)e G02-83-1023 Docket No. 50-397
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i Director of Nuclear Reactor Regulation Attention:
Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Comission Washington, D.C.
20555
Dear Mr. Schwencer:
Subject:
NUCLEAR PROJECT 2 EQUIPMENT SEISMIC QUALIFICATION
References:
1)
Safety Evaluation Report Related to Qe Operation of WPPSS Nuclear Project No. 2, Docket No. 50-397, NUREG-0892, Supplement No. 3, dated May 1983 2)
G02-83-590, G. D. Bouchey to A. Schwencer, Docket No. 50-397, " Justification for Interim Operation",
dated June 30, 1983 qualified by fuel load. Safety-related equipment required to operate WN be qualified by fuel load.We have identified certain equipment that need not The equipment identified at this time is described in attachments, along with justifications as to why WNP-2 can be operated safely until qualification is completed.
of plant changes which will require developmen)t of q We will act on these changes and develop final qualification documentation in a timely manner, which we believe is responsive to the Staff's require-ments in this area.
Very truly yours, j
. ww G. C. Sorensen, Acting Manager Nuclear Safety and Regulatory Programs KRW/sms Attachment cc: R Auluck - NRC
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- NRC Site J. Singh - EG8G R *_*:_: _ _...
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e TABLE Justification No.
Equipment Tyoe
-1 WMA Filters
-2 HPCS Diesel Generator
-3 MSIV
-4 SDV Modifications
-5 CRD Air Operators
-6 Heat Trace Control Panel
-7 Spray Pond Monitors
-8 Fatigue
-9 Wetwell Level Monitors O
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/hbID JIO-S-1 EPN:
WMA-FL-53A, 53B
==
Description:==
WMA-FL-53A and 538 are roughing filters for the critical switchgear air handling units WMA-AH-53A and 538, respectively.
filters.
They are continuously rolling type Safety Function:
WMA-FL-53A and 53B filter the air that heats or cools the critical switchgear room, battery and battery charging rooms, electrical equipment rooms, and the RPS rooms, which contain the M-G sets and motor control centers.
The filter itself is passive and need not operate during or after a seismic event.
Justification:
If the rolling filter fails due to a seismic event, heating or cooling is not immediately prevented.
The probable failure moce would be local yielding in filter media support grid.
Structural failure of the filter media support grid could cause a breach of the filter media.
This would have no near term operational effect on the cooling or heating performance of the air handling units. An alternate failure mode is stalling of the filter media.
term effect of this failure mode would be the Long-eventual clogging of the filter media.
If it does, there is a differential pressure switch to detect it and actuate a control room annunciation.
Even with a clogged filter, the reduced air flow could kee the rooms within their design temperature range.p In addition, there are also temperature monitors in each room which actuate a control room annunciation.
These temperature monitors are of the same manufac-turer and model as Seismically Qualified Safety-related monitors.
Safe shutdown is not prevented and there are alarms to indicate failure.
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5 JIO-S-2 Name:
HPCS Diesel Generator, engine, various control panels and compo.nents.
EPN:
DG-ENG-lC+
Safety Function:
To provide emergency power, in the event of loss of off-site power sources to the HPCS which supplies high pressure emergency, cooling water to the reactor pressure vessel, in order to maintain reactor core temperatures within specification limits..
Failure Effect:
A.
Effect on Primary Use Failures concurrent with loss of off-site power and LOCA with additional loss of redundant ECCS System (ADS) could cause fibw rate of emergency cooling water to be less than required to maintain reactor core temperatures within specification limits under high pressure accident conditions.
Justification:
The diesel generator on the Supply System Nuclear Pro-ject No. 2 High Pressure Core Spray System has been undergoing an extensive seismic qualification upgrade Original qualification was to IEEE-344, program.
1971.
This program, using a combination of test and analysis, has shown that the majority of essential
. components mounted on the diesel generator are quali-fied to the SQRT criteria.
However, a few essential components require additional tests or analyses to complete their qualification upgrade to current SQRT requirements.
Diesel generator systems are designed for high vibra-tion applications (i.e., locomotives, shipboard, etc.)
and by their nature (internal combustion engine) pro-duce vibrations often higher than seismic during normal running conditions.
We have confidence that the com-
~ ~ ~ ~ ~ ~ ~
ponents with incomplete documentation will not fail during a seismic event due to basic diesel design requirements and partial qualification information.
Operation of Supply. System Nuclear Project No. 2 prior to completion of this qualification poses no safety hazard because a redundant, single failure proof equip-ment path exists which provides safe shutdown without HPCS for those accidents for which HPCS is designed to operate.
This alternate safe shutdown path to provide core cooling would be accomplished by vessel depres-surization through ADS coupled with the low pressure LPCI mode of RHR operation and/or LPCS.
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JIO-S Continued Justification:
Sections 6.3.2.2.2, 6.3.2.2.3 and 6.3.2.2.4 of the FSAR (Continued) describe operation of this alternate shutdown path.
addition, Sections In of the FSAR discuss the controls and instrumenta detail.
Completion of the qualification documentation defined in the attached list will achieve seismic qualifica-tion of this alternate shutdown path.
These components will be completed prior to fuel load.
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QID EPN Description 233011 LPCS-P-1 Low Pressure Core Spray Pump 213064 LPCS-M-P/l Motor for LPCS-P-1 297009 MS-RV-1A-1D Main Steam MS-RV-2A-2D Relief Valves MS-RV-3A-3D MS-RV-3D,4A,4B,4C,4D MS-RV-4A-40 SB & SC Perform the MS-RV-58,5C ADS Function 018008 MS-AO-13M,13N Air Operators to 13P,13Q,135 ADS Main Steam 13U,13V Relief Valves 315008 MS-SPV-3DA Solenoid Pilot Valves that 3DB Actuate to Provide Control 4AA Air to Operate the Main 4AB Steam Relief Valve 4BA Operators that Provide 48B the ADS Function.
4CA 4CB 4DA 408 SBA 588 SCA SCB
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JIO-S-3 EPN:
MS-V-22A,B,C,D; MS-A0'-22A,B,C,D; MS-SPV-22A,B,C,0 serie MS-V-28A,B,C,D; MS-AO-28A,B,C,0; MS-SPV-28A,B,C,D serie
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Description:==
The equipment is the main steam isolation valves and operators.
They are large 26" isolation valves with air operators that fail shut in the event of loss of air.
The operators are equipped with large springs that return the valve to its closed (safe) position.
Safety Function:
These valves serve to provide main steam line isolation in the event of LOCA, MSLB, or breach of fuel accidents.
The safe position of these valves is closed for all design basis events.
Justification:
Dynamic qualification of these valves and operators to seismic and hydrodynamic loads has been achieved to IEEE-344, 1971.
A program to upgrade the valve and operator qualification to meet the criteria of IEEE-344, 1975, is in progress; however, final upgrade operability demonstration documentation, may,not beincluding available prior to fuel load.
System testing has confirmed the operability of these valves to normal conditions which, in themselves, produce large vibratory forces.
Stress factors associated with the seismic and hydrodynamic loads have already been considered and found acceptable.
In addition, in-plant static deflec-tion testing at maximum seismic and hydrodynamic loads has successfully been completed demonstrating operability.
Based on this, we believe that these valves will accom-plish their safety function (i.e., closed on demand) when required as these valves spring return to close upon loss of air pressure.
Operation of WNP-2 is justified based on the initial qualification to IEEE-344, 1971, of the valves, and demonstrated normal and faultedthe fail-safe service operability testing as part of the Startup System Testing Program.
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/ hb Jf0-S-4 EPN:
See Attached.
==
Description:==
See Attached.
Safety Function:
These components are part of a scram discharge modifi-cation package.
They contribute to ensuring proper control of control rod drive discharge water in the event of a reactor scram.
Justification:
Qualification testing and analysis of these components are scheduled to be complete prior to the fuel load schedule of WNP-2.
However, the final report docu-formed will not be available from the supplier unt the first quarter of 1984.
This change is part of the BWR Owners Group Modification package and deferral of receipt of final documentation until after fuel load is consis-tent with requirements for other NT0Ls.
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OID EPN Description Safety Function 361501 CRD-V-180 Valve CRD-V-181 Valve 018005 CRD-AO-180 A1.r Operator CRO-AO-181 Air Operator 315026 CRD-SPV-9 Solenoid Pilot Valve CRD-SPV-182 Solenoid Pilot Valve 050101 CRD-LIS-601A Level Indicating CRD-LIS-601B Switch CRD-LIS-601C CRD-LIS-6010 i
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JIO-S-5 EPN:
CRD-AO-10,11
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Description:==
Air Operators Safety Function:
Containment isolation and provide proner control of CRD water to allow r,eactor scram function.
Justification:
Static analysis has been completed on the yoke assembly for CRD-V-10 and -11.
However, required supplementary seismic qualification covering the air operators (-AO-)
has not been completed because of insufficient manufac-turer's documentation.
Based upon the valve yoke qualification, a successful in-situ static deflection operability test was performed to the actual piping loads.
We are investigating potential procurement of complete valve assembly qualification data from another utility.
Interim operation of WNp-2 is justified based on the successful static deflection operability demonstration test.
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JIO-S-6
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EPN:
SW-CP-HTP-8A/AA SW-CB-H1,H2,H3
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Description:==
Heat Trace Control Panel Safety Function:
The safety function of this panel is to control the electrical heat trace to the Standby Service Water System cooling lines to the emergency diesel generators.
System This panel is seismically mounted and structurally
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Justification:
qualified.
is not complete.However, internal component qualification Failure of this control panel may result in failure of the heat trace for the service water lines.
During the winter months, this may result in freezing of the cooling water lines with loss of cooling water to the emergency diesels.
Each heat trace is provided with a temperature monitor which initiates an annunciator in the main control room if the temperature at the trace becomes too low.
With this indication, the operator will actuate the service water pump supplying these lines.
Keeping the water moving in these lines prevents freezing until the heat trace is functional again.
Based on alarm indication and operator action in the event of failure of the power supply, WNP-2 can be operated safely.
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JIO-S-7.
'd 1 EPN:
SW-LTD-1A, -1B, -lC, -ID
==
Description:==
Spray Pond Level Monitors Safety Function:
The safety function of these instruments is to monitor spray pond water level and control makeup water supply from the Tower Makeup System such that a 30-day inven-tory (technical specification requirement) always -
exists in the ponds.
e level monitors.
Each pond is provided with two Justification:
The detectors are installed in support tubes which assure they are placed at the proper depth in the spray pond.
There is cletrance between the support tube and detector assembly which could allow impact between the detectors and the support tubes during a seismic event.
The qualification testing did not duplicate the support tube / detector interface conditions and, thus, does not represent field conditions.
A design modification is being implemented to add space fillers between the detector and the support tube to prevent impacts from occurring.
This will then allow use of previous test data.
This package is being held open pending completion of the field modification.
The spray ponds always have a 30-day water supply.
This supply will exist at the time a seismic event occurs.
If both level sensors in each pond fail at this time, a sufficient water inventory is available in the ponds necessary to supply cooling water to those systems responding to accidents for a sufficient period even with the automatic makeup system not functioning.
In the event that detector damage occurs, operator action will be utilized to manually control makeup water to the ponds.
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JIO-S-8 N
C-EPN:
See Attached.
==
Description:==
See Attached.
Safety Function:
See Attached.
Justification:
The qualification packages for these components are complete with the exception of addressing fatigue.
The seismic and hydrodynamic maximum loads have been addressed and these components are capable of performing to these levels.
Incomplete in the existing documentation is the addressing of the number of cycles and the resulting fatigue.
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The WNP-2 qualification process has identified six component types for which adequate fatigue life cannot be demonstrated for the load combinations specifically required for WNP-2.
The general fatigue.
evaluation conservatively requires that each component subject to seis-mic and hydrodynamic loads be capable of withstanding 13 500 cycles of SRV transient, 60 cycles of SSE transient and a reserve o,f 2,000 cycles for postulated LOCA transient.
The Supply System is committed to dynamically qualify components fatigue life for complete 40-year operation. identical or similar ing criteria will be used to justify two-year operation:In the interim, the follow-1.
20 cycles of SSE transient; 2.
675 cycles of SRV transient; 3.
A detailed discussion of each transient is presented below.
The number of cycles of peak response to be considered for a single seism event is ten cycles.
combined with 1 SSE transient.The required 60 cycles represents 5 OBE transients The Supply System will commit to reevaluate of the indicated fatigue testing.the affected equipment should tw The total number of cycles of SRV transient to be considered for fatigue is 13,500 for the life of the plant.
This is equivalent to 675 cycles of transient in a two-year period.
This number of evelae approximately 110 SRV transients for the two "
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more than 100 SRV transients be required i equipment will be reevaluated.
The postulated loss-of-coolant accident transient loadings are based on low probability, large break area, high energy line breaks.
Recent materials and fracture mechanics technological developments have demon-instead leak before they break.strated that these large breaks will not oc Fracture mechanics evaluations have demonstated repeatedly that large margins exist between the development
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of detectable leaks and complete pipe rupture.
It is recognized that systems subjected to material erosion and intergranular stress corrosion may not exhibit these large margins; however, these deteriorating mechanisms require substantial time to affect the system integrity.
Based on this discussion, and the fact that WNP-2 piping has been subjected to induction heat stress improvement at locations susceptible to stress postulated large break LOCA occurrence within the first tw S
I operation is negligible and, therefore, feels that not considering the transient in the interim fatigue evaluation for the affected components will not compromise the overall safety of the plant.
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IQID EPN Description Safety Function 248002 CSP-POS-V/8/P10 Position Switch Reg. Guide 1.97 Cat. I 11 12 13 2
3 4
9
-V/10/P1 P2 P3 P4 F9 P10 P11 P12 P13
-V/7/P1 P11 P12 P13 j
-V/7/P2 P3 P4 P9
-V/8/P1 1 277007 CMS-RE-27E, -27F Radiation Element Reg. Guide 1.97 Cat. 2 324006 RHR-V-60A, B Solenoid Valve
-75A,8 Primary and secondary containment RRC-V-20 isolation of sample lines.
3G1009 HY-V-20A, 8 Solenoid Valve
-36A B Primary and secondary containment CAS-V-453 _ _.-_._.
isolation of hydraulic system lines 382003 E-X-103A,B,C,D Electrical Penetration Provide conduction path into primary containment and isolate primary containment
( 382003 E-TRS-X104A/0 Terminal Blocks in B
prinary containment Provide electrical conductivity C
electrical penetration 0
-X107A/0/1 B/0/1
-X105A/0/1 2
-X1050/0/1 2
-X105C/0/1 2
1
_QID EPN Description Safety Function 382003 E-TRB-X1050/0/1 (cont) 2
-X107A/0/1
-X107A/0/2 E-TRE-X104A/I B/I C/I D/I
-X105A/I B/I C/I e
D/I
-X107A/I B/I 110004 CAC-EHO-FCV/1A Electrical / Hydraulic Containment atmosphere control IB valve operator
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/2B
/3A
/38
/4A
/4B
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/5B CAC-M-FCV/1A,18
/2A,2B
/3A,38
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EPN:
CMS-LT-3,
-4, -5 CMS-LE-3A, -3B, -4A, -4B. -5A, -5B
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Description:==
Wetwell Le.el Monitors and Level Elements Safety Function:
Provide operator indication of suppression pool water level post-accident condition.
Justification:
See attached justification from Environmental Qualification Report, which dismisses CMS-LE-3A,B.
but also applies to the other EPNs listed above.
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<UIPMENT JUSTIFICATION #7 1.0, COMPONENT IDENTIFICATION EPN:
CMS-LE-3A, 3B
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Description:==
Suppression Pool Wide Range Level Monitoring Component Type:
Pressure Transducer Manufacturer /Model:
Electro $yn/962 2.0 ACCIDENT CONDITIONS
- Temoerature Relative Humidity Accident Profile:
- 1
- 2 Rev. 2 Use Code:
1 Operability Time:
4320 Hours Radiation Zone:
C500 Zone Dose:
9.0 x 107 Rads The following exceptions apply to CMS-LE-3A only:
Temperature:
200 F max Pressure:
Dependent on suppression pool level Humidity:
Submerged Radiation Zone:
C435
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3.7 x 106 rads
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3.0 COMP 0NENT SAFETY FUNCTION l
CMS-LE-3A and CMS-LE-38 provide verification of suppression pool water level and long-term surveillance in accurdance with the guidelines of Regulatory Guide 1.97.
Water level indication provides verification of the availability of water for the ECCS and a diverse indication of breach of the primary system (LOCA).
CMS-LE-3A measures pressure at the bottom of the suppression pool, and CMS-LE-3B measures pressure in the suppression chamber air space.
The signal from each of these pressure transducers is sent to an electronics package in the control room which determines the suppression pool water level which corresponds to the indicated differential pressure.
7199f/2
4.0 QUALIFICATION STA.a5 4.1 Summary of Qualification Status The level monitoring system is being custom built for WNP-2.
The qualification plan is currently being completed, and testing to verify qualification is scheduled.
This system is scheduled for installation prior to fuel load, but it will not be demonstrated to be qualified prior to installation.
This level monitoring system has been des'igned to function in nomal and accident environments.
Radiation and temperature resistant materials have been specified for the transducer sehls, lead wires, cable (and shrink tubing), junctiun box gasket, and connections.
The flexible and rigid conduits containing the transducers and cables are water-tight.
The junction box is above the water level and is designed to protect the connectors from any postulated water spray.
Based on this design, the level monitoring system is expected to perfom its function.
4.2 _P_arameters Requiring Justification Radiation dose, temperature, pressure, relative humidity, and submergence.
5.0 JUSTIFICATION FOR INTERIM OPERATION The conditions for which suppression pool w' ter level would require wide a
range level instrumentation involve the long-tem passive failure of an l
ECCS inside the primary containment coincident with a LOCA.
Since this assumes a passive failure in addition to the accident scenario, which is not considered in JIO, CMS-LE-3A and CMS-LE-38 are not required.
The suppression pool water level can therefore be continuously monitored with narrow range level instrumentation.
~ ' Qualified suppression po'ol' narrow range instrumentation is available at this time.
CMS-LT-1 and CMS-LT-2 are qualified and provide'suppressio'n~~
pool level indication over the range of 31' + 27".
The suppression pool nomal operating level is 31' 1,2".
t 6.0 CONCUISION
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Interim operation is justified on the basis:
j Since no single active o_r cdditional long-term passive failure was assumed for the suppression pool, its water level will remain within the narrow range instrumentation.
In other words, water is not 1~ost Rev. 2 due to a break in the ECCS.
The qualified suppression pool narrow range instrumentation system will provide adequate level monitoring until environmental testing can be completed on the wide range instrumentation.
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