ML20215J895
| ML20215J895 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/30/1987 |
| From: | Liaw B NRC OFFICE OF SPECIAL PROJECTS |
| To: | Zwolinski J NRC OFFICE OF SPECIAL PROJECTS |
| References | |
| NUDOCS 8705080318 | |
| Download: ML20215J895 (16) | |
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UNITED STATES g
- NUCLEAR REGULATORY COMMISSION y
WASHINGTON. D. C. 20555 5
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APR 3 01987 Docket Nos.: 50-327 and 50-328 MEMORANDUM FOR:
John A. Zwolinski, Assistant Director for Projects TVA Projects Division Office of Special Projects FROM:
B. D. Liaw, Assistant Director for Technical Programs TVA Projects Division Office of Special Projects
SUBJECT:
SEQUOYAH SAFETY EVALUATION REPORT
References:
A.
Letter from B. J. Youngblood, Director, PWR Project Directorate #4, Division of PWR Licensing-4, to Mr. S. A. White, Manager of Nuclear Power, TVA, dated December 5, 1986, subject " Transmittal of Draft Safety Evaluation on Equipment Qualification for Sequoyah, Units 1 and 2."
8.
Letter from R. L. Gridley, Director, Nuclear Safety and Licensing, TVA, to S. Ebneter, NRC, dated March 24, 1987, subject "Sequoyah Nuclear Plant (SQN)
- Compliance with 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants."
A review of the documentation supporting TVA's certification for the nine confirmatory items identified in the draft safety evaluation report (SER) included in Reference A. has been conducted.
In addition, during the equip-ment qualification (EQ) inspection at Sequoyah April 6-10, 1987, discussions were conducted with TVA concerning the nine confirmatory items. Based on the review and the discussions with TVA, the following comments are provided.
Confirmatory Items:
1.
Resolution or staff approval of the main-steam-line break with superheat release and its effect on the environmental qualification of equipment in the east and west valve vault rooms (A1, A2, A10, and All).
Comment: TVA's resolution is currently undergoing staff review and will be the subject of a separate SER dealing with the issue.
In anticipation of approval of the TVA proposed resolution, TVA has already implemented j
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John A. Zwolinski APR 3 01987 or is implementing EQ changes required by their resolution of this issue.
Since resolution of this issue will be the subject of a separate SER, it is not included as a confirmatory item in the final EQ SER.
2.
Completion of all EQ Fieldwork Comment: During the April EQ inspection, the NRC inspectors reviewed scheduled completion dates for outstanding fieldwork and determined that TVA still has several items of fieldwork to complete.
The inspectors also determined that TVA has a tracking system to assure completion of the work prior to restart. Completion of fieldwork is a confirmatory item in the final EQ SER.
3.
Mainsteam Vault Submergence Review Comment: During the April EQ inspection, the NRC inspectors reviewed significant condition reports (SCR) SQNEQP8635, Revision 2, and SQNEQP8661, Revision 1, and determined that only fieldwork remaining regarding this item as stated by TVA in Enclosure 2 of Reference B.
In addition during the June 1986 EQ inspection, the inspectors reviewed eight EQ binders relative to this item.
Since only fieldwork remains for resolution of this item and it is being tracked by TVA as part of the fieldwork of item 2 above, this item is not included as a separate SER confirmatory item.
Resolution of this item will be followed as part of the fieldwork confirmatory item.
4.
Management Review of EQ Binders Comment: During the four EQ inspections of 1986 and the April 1987 EQ inspection the NRC inspectors determined that all SQN EQ binders had undergone management review. TVA's response is considered acceptable.
5.
Supplemental Vendor Information Comment: During the April 1987 inspection, the inspectors reviewed SCR SQNEQP8542, Revision 1, and "10 CFR 50.49 Cable and Splice List,"
SQN-CASL-001, dated March P7, 1987, and determined that this confirmatory item was complete. TVA's response is acceptable.
6.
Cable Load Study Comment: During the April 1987 inspection, the inspectors reviewed Quality Information Request / Release (QIR) SQP-87-169 and a sample of the April 3, 1987, computer printout for the " Cable Average Conductor Temperature Analysis Testing (CACTAT) Study for mild-harsh-mild and harsh 50.49 cables."
Additionally the inspectors reviewed two (SQN-EQ-CABL-016 and -032) of the six EQ binders which were affected by changes in cable ampacity tables and determined that appropriate revisions were included in the binders.
Completion of this item is acceptable.
a John A. Zwolinski APR 3 01987 7.
Inside Containment Flcod Analysis for 5-minute Operability Comment: The inspectors reviewed SCR SQNEQP8515, Revision 0, and its associated SCR completion verification; as well as, Office of Engineering calculation number EQP-27 pertaining to this confirmatory item. The inspectors determined that this item is complete. TVA's response is acceptable.
8.
Verification of Instrument Accuracy Calculation Comment: The NRC inspectors reviewed the three EQ binders (SQN-EQ-XMTR-001 and -004 and SQN-E0-IPT-002) affected by this confirmatory iten during the June 1986 and April 1987 inspections and determined that this item was complete. TVA's confirmatory response is acceptable.
9.
Finalization of the EQ Master List Comment: The inspectors reviewed the TVA letter from J. A. Domer to V. Stello, Jr., dated August 13, 1986 which included the 10 CFR 50.49 list for SQN.
In addition during the January 1986 inspection, the NRC inspectors reviewed the Master List that existed at that time; as well as, the SQN methods of controlling the list. Since the reviews have identified no problems with either the January list or the August list and no deficiencies with the methods of controlling the list, TVA's confirmatory respnse is acceptable.
Based on the documentation reviews discussed above and discussions with TVA, the TVA response to confirmatory items 4 thru 9 is acceptable. With the understanding that confirmatory item I will be covered by a separate SER, it is not included in the attached, corrected, final EQ SER. Additionally, since the reviews determined that confirmatory item 3 has only fieldwork remaining, which is being tracked under confirmatory item 2, item 3 is not included in the final E0 SER. Therefore, the only confirmatcry item remaining in the fina' EQ SER is completion of all fieldwork.
It is recommended that the attached, corrected, EQ SER be issued with the one confirmatory item. When TVA submits its certification for completion of all fieldwork, the staff will review a sample of the items to verify completion prior to restart.
73
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TVA Projects Division Office of Special Projects
Attachment:
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. John A. Zwolinski 4_
DISTRIBUTION:
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-NRC"PDR Local PDR JAxelrad SEbneter SRichardson BDLiaw GZech, RII SRConnelly, 0IA BHayes, 01 CJamerson.
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DATE :4/.29/878 b
- 4/M/878
- 4/d/87 I
ENCLOSURE 2-5 ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY 5.1 Introduction A licensee must demonstrate that equipment that is used to perform a necessary-safety function is capable of maintaining functional operability under all service conditions postulated to occur during its installed life for the time it is required to operate. This requirement (which is in General Design Cri-teria (GDC) 1 and 4 of Appendix A and Sections III, XI, and XVII of Appendix B to 10 CFR 50) is applicable to equipment located inside as well as outside. con-tainment. More detailed requirements and. guidance relating to the methods and procedures for demonstrating this electrical equipment capability are in 10 CFR 50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants"; in NUREG-0588, " Interim Staff Position on Environmental Qualification on Safety-Related Electrical Equipment" (which supplements IEEE Standard 323 and various NRC Regulatory Guides and industry standards); and " Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors" (Division of Operating Reactors (DOR) Guidelines).
5.2 Background
On February 8, 1979, the NRC Office of Inspection and Enforcement (IE) issued to all licensees of operating plants (except those included in the systematic evaluation program (SEP)) IE Bulletin (IEB) 79-01, " Environmental Qualification of Class 1E Equipment." This bulletin, together with IE Circular 78-08 (issued on May 31, 1978), required the licensees to review the adequacy of their envi-ronmental qualification programs.
On January 14, 1980, NRC issued IEB 79-01B, which included the 00R Guidelines and NUREG-0588 as attachments 4 and 5.
Commission Memorandum and Order CLI-80-21, issued on May 23, 1980, stated that licensees must meet the 00R guidelines and portions of NUREG-0588 regarding environmental qualification of TVA V0L 2 SEC 5 5-1 01/09/87
safety-related electrical equipment to satisfy those aspects of GDC 4.
Supple-ments to IEB 79-018 further clarified and defined the staff's needs.
These supplements were issued on February 29, September 30, and October 24, 1980.
In addition, the staff issued to all licensees Orders dated August 29, 1980 (amended in September 1980) and October 24, 1980. The August Order required that the licensees provide a report, by November 1, 1980, documenting the qualification of safety-related electrical equipment.
The October Order required licensees to establish, by December 1,1980, a central file location for the maintenance of all equipment qualification records.
ThestaffissuedaSafetyEvaluationReport(SER)onevirqgmgtfqualifica-tion of safety-related electrical equipment to TVA dn 1981.
T$1sSER directed TVA to "either provide documentation of the miss' ng qualification
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information which demonstrated that safety-related equipment meets the 00R
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Guidelines or NUREG-0588 requirements or commit to a cor'rective action (requali-fication, replacement (etc))." TVA was required to respond to NRC within 90 days of receipt of the SER.
In response, TVA submitted additional information regarding the qualification of safety-related electrical equipment.
This infor-mation was evaluated for the staff by the Franklin Research Center (FRC) to (1) identify all cases where TVA's response did not resolve the significant qualification issues, (2) evaluate TVA's qualification documentation in accor-y dance with established criteria to determine which equipment had adequate docu-Q mentation and which did not, and (3) evaluate TVA's qualification documentation f
for safety-related electrical equipment located in harsh environments required
\\h for implementation of TMI Lessons Learned.
FRC issued a Technical Evaluation Report (TER) on March 31, 1953. The staff issued an SER on April 26, 1983, d
with the FRC TER as an attachment.
t A final rule on environmental qualification of electric equipment important to l
safety for nuclear power plants became effective on February 22, 1983.
This l
rule, 10 CFR 50.49, specifies the requirements for electrical equipment l
important to safety located in a harsh environment.
In accordance with this rule, equipment for Sequoyah Units 1 and 2 may be qualified to the criteria specified in either the 00R guidelines or NUREG-0588, except for replacement equipment.
Replacement equipment installed after February 22, 1983, must be TVA VOL 2 SEC 5 5-2 01/09/87
"S.
qualified in accordance with 10 CFR 50.49, using the guidar.ce of Regulatory Guide 1.89, unless there are sound reasons to the contrary.
The staff met with each licensee for whom FRC had prepared a TER to discuss all remaining open issues regarding environmental qualification, including the acceptablility of the environmental conditions for equipment qualification purposes, if_this issue had not yet been resolved.
On May 10, 1984, the staff and TVA met to discuss TVA's proposed method to resolve the environmental qualification deficiencies identified in the staff's April 26, 1983, SER and FRC's March 31, 1983, TER.
Discussions also included TVA's general methodology for compliance with 10 CFR 50.49.
The minutes of the meeting and proposed method of resolution for each of the environmental qualification' deficiencies are documented'in submittals by letters dated March 26, December 23, 1985 and January 29, 1986.
On August 21-22, 1985, TVA shut down both Sequoyah units because of concerns that documentation at TVA nuclear sites might be inadequate for environmental qualification of electrical equipment within the scope of 10 CFR 50.49. This decision was based on the results of a TVA Management review of the environ-mental qualification activities for compliance with 10 CFR 50.49 (conducted by TVA staff and Westec Services, Inc.).
Based on this decision and the results of the review, TVA initiated an in-depth program to ensure that environmental qualification of all electrical equipment within the scope of 10 CFR 50.49 was established at Sequoyah and all other TVA nuclear sites.
5.3 Evaluation 5.3.1 Summary of Review j
The staff evaluation of TVA's electrical equipment qualification program is I
based on the results of a review of:
(1) TVA's proposed resolutions of the equipment qualification deficiencies identified in the SER and TER; (2) TVA's compliancewiththerequiregentsof10CFR50.49;(3)TVA'sCorporatgNuplgr j l
Performance Plan, Revision 4, and Sequoyah Nuclear Performance Planytsubmittet
-:- 1"1y ",11^'); and (4) the staff's equipment qualification audit on l
l TVA VOL 2 SEC 5 5-3 01/09/87 7
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7 CW November 18-22, 1985, and the staff equipment qualification inspections gg 8 h January 6-17, February 10-14, June 23-27, and December 1986, and k
1987.
lg 5.3.2 Proposed Resolutions of Identified Deficiencies TVA described its proposed resolutiens for the equipment environmental qualifi-cation deficiencies identified in the SER and the TER in submittals dated March 26 and December 23, 1985, and January 26, 1986.
During its May 10, 1984, meeting with TVA, the staff discussed the proposed resolution of each deficiency for eachkuipment item identified in the TER and found TVA's approach for re-solving the identified environmental qualification deficiencies acceptable.
The majority of deficiencies identified were documentaion, similarity, aging, quali-fied life, and replacement schedule.
All open items identified in the SER were also discussed, and the staff found TVA's resoluti.on of these items acceptable.
TVA's approach for addressing and resolving the identified deficiencies includes replacing equipment, performing additional analyses, using additional qualifica-tion documentation beyond that reviewed by FRC, obtaining additional qualifica-tion documentation, and determining that some equipment is outside the scope of 10 CFR 50.49 and need not be environmentally qualified (equipment located in a mild environment).
The staff discussed the proposed resolutions in detail, on an item-by-item basis, with TVA during the May 10, 1984, meeting.
Replacing or exempting equipment, for an acceptable reason, is clearly an acceptable method for resolving environmental qualification deficiencies.
More lengthy discussions with TVA concerned the use of additional analyses or docu-mentation. Although, during the meeting, the staff did not review the addi-tional analyses or documentation, the staff did dicusss how analysis was being used to resolve deficiencies identified in the TER, and the content of the additional documentation to determine the acceptability of these methods.
On November 18-22, 1985, the staff and a consultant from EG&G Idaho, performed an audit of the Sequoyah electrical equipment environmental qualification binders, and inspected s (ected equipment.
On Jaunary 6-17, February 10-14, June 23-27, and December 8 1986, and A/Nl 0 Y,1987, the staff and its consultants g
al Laboratories wi,..c..t pd"'ntimW pected the
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Sequoyah binders and selected equipment, and reviewed Sequoyah's implementation g
of the 10 CFR 50.49 program.
On the basi's of its discussions with TVA, the review of the submittals, and the audit and inspections, the staff finds TVA's approach for resolving the identified environmental qualification deficiencies acceptable.
5.3.3 Compliance with 10 CFR 50.49 All equipment that is located in a potentially harsh environment and is required tomitigatetheconsequencesofadesign-basisevent(DBE)atSequoyahkas eenidentifiedinaccordancewith10CFR50.49(b)(1).pheequipme3 ems dentified%y reviewing all systems on which the safety analysis in the FSAR i
is dependent. Other systems or equipment necessary to support these systems N also identified d y 7 M.
p efed i
cay From the safety systems identified above,pa survey f the safety-related equip-mentwithinthepotentiallyharshenvironmentMhatresultedfromaDBE,was-condueted.
This survey was conducted using electrical instrument tabulations, j
mechanical piping drawings, mechanical heating and ventilation drawings, instru-mentation and control drawings, electrical equipment drawings apd con g y nd grounding drawings to identify the safety-related components.4 ghe equipment qualification = nriff:d by a field survey of the installed components to certify proper correlations between the qualification documents and the in situ equipment.
3 g gig em, h tb a DBEs in the area covered, 10 CFR 50.49 are high energy line breaks (HELBs) both inside and outside of containment and loss-of-coolant accidents (LOCAs).
Equipment in the 10 CFR 50.49 program was evaluated for the harsh environments through which it must function and/or not fail. These environments include flooding both inside and outside containment as a result of a DBE.
also evat ated other accidents that In the Se uoyah FS R (Chapteg 15), TVA di not fi the 10 R 50.49 DBE definiti as inter etedaboveputthathave everethan\\thoseencongteredduring the potenti 1 to pro ce envir ments more norm 1 operation or an icipated operational occurrences.' These accidents are TVA VOL 2 SEC 5 5-5 01/09/87
- p. t L } U Sh MfdCNC' SeL the waste ga decaytapnGDT)ruptur[hefuelhandlyaccident[A),an These thre / events do not produce enerator)6berupture(SGTR).
the steam emperature or pressure epsironments, and,t'he radiation' environment's unusual r
j associ4ted with them are not sig'nificant.
Radiation doses to equipment ne'ces-
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sary for mitig7 on of these, events is less than 104 rads. /
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T 10 CFR
.49 DBEs at S quoyah that pro uce harsh env ronments are L CAs, H LBs insi containment and HELBs outsi e containmen.
TVA environmental data drawings are design output documents that identify and define the conditions of all harsh zones that contain 10 CFR 50.49 scope equip-ment.
These harsh zones result from the DBEs.
All environmental parameters necessary for design, procurement, and qualification of equipment in accordance with 10 CFR 50.49 are specified on these drawings.. These parameters include normal, abnormal, and accident' values for temperature, pressure, relative humid-ity, radiation (expressed as a 40 year integrated dose and an accident dose),
flooding level (from a LOCA and HELB including contribution from spray), and spray chemistry.
LOCA and HELB pressure, temperature, and relative humidity profiles are provided. The environmental parameters shown on the drawings are derived from a number of supporting calculations that are referenced on the
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drawings.
TVA's approach for identifying equipment within the scope of 10 CFR 50.49(b)(1) is in accordance with the requirements of that paragraph,.and therefore is acceptable.
The paragraphs below summarize the method used by TVA for identification of electrical equipment within the scope of 10 CFR 50.49(b)(2), non-safety-related electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions.
Non-safety-related electrical equipment exposed to harsh accident environments must not fail in a manner that can prevent safety-related electrical equipment from performing its safety function.
In response to IE Notice 79-22, TVA evalu-ated non-safety-related devices for their potential to adversely affect safety-related devices as a result of environmentally induced failures.
Flow, control, TVA VOL 2 SEC 5 5-6 01/09/87
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FSAR TVA emme also evaluated other accidents in chapter 15 of the Sequoyah that did not fit the 10 CFR 50.49 DBE definition as interpreted above, but that have the potential to produce environments more severe than I,
those encountered during normal operation or anticipated operational These accidents are the waste gas decay tank rupture yg b
(WGDTR), the fuel handling accident (FHA), and the steam gen occurrences.
r ith pressure environments, and the radiation environments associated wRa h
rupture (SGTR).
The FHA results in them are not significant.
y mitigation of these events are less than 104 rads.
relatively mild radiological consequences that are restri
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(ABGTS) charcoal beds in both units.
10 CFR 50,49 affected by the FHA is reflected in the category and h
operating times document for Sequoyah and is qualified to more hars environments than that produced by the FHA.
In summary, the 10 CFR 50.49 DBEs at Sequoyah that produce harsh inside environments are 4 those events which are LOCAs, HELBsThe FHA, occurring in the containment, and HELBs outside containment. fuel handling area, is which produces a harsh environment.
1Revise page 5-8, the first, third, and fourth full pa agraphs in the of f the page, whiqh address environmental guali icat opo ed 3.
j 1
7.
t wit 'n the sedpe of Regulatory Guide.(RG) enter th rimarily (ocused on Aimplifying and cla ifyiqual(fic ion of.
pquipm tevisi s are urrent lanci future sc'dpe of environmenta Ad ap' parent word) processing error,s correcte in the c scuss,on of and the 1.97 equipmept.
f est p ragraphjby iniserting a negative in the third sentencel, t ird a d fourt% persgrapSs are combined following revision for i
tinu ty of discussion. kThe proposed text attempts to elim nate ly confusing statements by more closely reflecting cu'prent; c
pqenti p
liance to 10 CFR 50.49, " Environmental Qualification of El Plants.'$ Additionally,act to current od C, ure Pfogram s ope as pr sen fu Eq'p pmen' Import details are remov d which mdy be subjermane t' the subs}ance of the 10 C re e one interact ons being discussed.
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/or whi h are not ch nge a an RG 1. 7 prose 9
and logic diagrams for all safety-related process systems were reviewed to determine all interfaces with non-safety-related equipment.
Detailed wiring diagrams were used if the nature of an interface was not clear from the control and logic diagrams.
Each interface with non-safety related equipment was evalu-ated for its potential to adversely affect safety functions, and the results were documented.
The result of this study showed that six non-Class 1E devices (three per unit in the residual heat removal (RHR) system) have the potential to adversely affect RHR. However, a failure modes evaluation of these devices concluded that the devices would not adversely affect RHR if their cables were environmentally qualified. These cables are environmentally qualified and have been added to the approporiate binders and the "10 CFR 50.49 List" to ensure their continued qualification.
The evaluation also identified cases where disruptive signals could be generated, but in each case the operator has sufficiant indication of the event and sufficient time to take corrective action.
TVA performed separate evaluation of the Class 1E power system to investigate the effects of environmentally induced failures. The design basis of the Class IE power systems includes protective features for coordinated, selective clearing of single random faults and overloads.
Most failures of non qualified equipment from environmental causes will occur in a random fashion.
The Class 1E power system is therefore adequately protected by its own design for most environmentally induced failures. The operation of this electrical protection was examined in analyses done to verify the protection of primary containment electrical penetrations and in analyses done to identify associated circuits as defined for 10 CFR 50, Appendix R.
The protection has been shown to satisfy i
its design basis.
Submergence and spray effects may, however, cause multiple non qualified electrical equipment and cable termination faults.
This type of failure is outside the design basis of the Class IE power system.
Devices and junctionboxesexposedtocontainmentsprayortosubmergenceOsYej(outside j
l containment that are not qualified for these conditions have been icientified.
Evaluations of the effects of multiple faults from these circuits on the abilityj of the Class 1E power system to provide power to essential equipment show thatj unacceptable degradation of the Class 1E power system would not occur. r,/
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TVA VOL 2 SEC 5 5-7 01/09/87
i The staff finds the methodology being used by TVA acceptable because it provides reasonable assurance that equipment within the scope of 10 CFR 50.49(b)(2) has been identified.
With regard to 10 CFR 0.49(b)(3), TVA evaluated existing syst arrangements and id tified equipmen for the variab es defined n RG 1.97, vision TVA has sube tted for staff eview a report utlining th results of he rev and schedules for modificati s.
Because the review is t complete, one of the equipment temsjointlyw hin the scope of NUREG-073 and RG 1.97 ave be n WhenkheRG1.97reportandeqipment ists f '9 included in he 10 CFR 50.
scope.
inalizedandacoptedbythestaff,ap opriate O p contained the ein have been o
equipment not eady in the CFR 50.49 sco will be added in ac ance with the RG 1.97 implementation schedule.
TVA will complete environmental qualification of the applicable FSAR Class IE-l' designed instrumentation and the FSAR post-accident monitoring (PAM) instrumen-tation before plant restart.
For those instruments already added to the plant because of a commitment to meet post-TMI requirements (NUREGs-0578 and -0737),
'S TVA will complete its environmental qualification in accordance with its j
j Y j responses to those NUREGs or any extension granted with respect to those
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i r that in r ntation t considered rable or not inst lied but w 1 be i
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not hpcause of RG 1. 7 or post-TMI, NUR s, enviro ntal
'l qua ification 11 be complet when the equip nt is installed a operabl.
A t designed a\\s Class 1E nor incl {ded in 6
he For i trumentation at the plants N(
origina PAM instrume ation set tha will be Categ y 1, RG 1.97 instrumenta-tion, TV will complete nvironmental alification i accordance with the imple-t
.97 provided n TVA's respons to Generic Letyr 82-33 cheduleforRG(1983).
mentation (September 2, for Sequoya TVA has investigated whether proper consideration of the equipment used in execution of Emergency Operating Instruction (E01) requirements has been The following given in the development of the 10 CFR 50.49 equipment scope.
l were considered
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01/09/87 5-8 TVA V0L 2 SEC 5
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With regard to 10 CFR 50.49(b)(3). TVA evaluated existing system gand identified equipment for the variables defined in RG arr 1.97 report outlining the results of the review and schedules for Dg modi'fications has been submitted to the staff for review. Recause the report is still being reviewed, some of the equipment items jointly within the scope of NUREG-0737 and RG 1.97 have not been included in the 10 CFR 50.49 scope. When the RG 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 RG 1.97 implementation schedule.
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For instrumentation at is not considered operable or not installed but that will be complete in accordance with the implementation schedule for RG 1.97 or post-THI NURECs, environmental qualification will be complete
.,f hW when the equipment is installed and operable. For that instrumentation that exists at the plants but that was not inci in the original FAM(rv
-F 1.97 instrumentation.
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instrumentation set but that will be Category TVA will complete environmental qualification accgedance with the implementation schedule for RG 1.97.
Reseonse to confirmatory It- -
Under section 5.4 ' onclusions," of the draf t SER, nine confimatory items The e aff stated TVAgwould be requ$ red to certify were i sted'on page
-10.
that t. issues had,en complet. or resolved Hofore restart.
The f 11owing provide certification of completion or resoluti n of these items exc pt as indicat Remaining \\ fieldwork associated with afirstthreeitemslbelowis reflected in attachment R to enclosure 1 and will'be completed in accordance
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with program requirements before restart of the affected< unit.'
Confirmatory It
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Regolution or staff approval of the main-steam-line break with (1) superheat release and its effect on the environmental qualification of Aquipment in the east and west valw vault rooms (A1, A2, A10. All)
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TVA R'esponse: TVk. resolution (submittal) currently undergoing NRC
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staff review.
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a (1) Does the plant operator have reliable instruments to identify and mitigate the consequences of DBEs?
(2) Have those instruments been marked to indicate their importance to the plant operator?
TVA's installed PAM indicators are specifically identified to the main control room operator. The indicators are marked either P1 or P2, which indicates the function these indicators fulfill as PAM channel 1 or PAM channel 2.
This method of marking the indicators on the main control room boards shows as their import-ance (rather than requiring that they be singled out in the plant procedures as being EQ safety-related).
These installed PAM indicators are served by instruments (e.g., transmitter, etc.) that are qualified to meet the 10 CFR 50.49 requirements. When other activities are implemented (in accordance with NUREG-0700 and RG 1.97),
instruments presently installed but not requiring specific identification and qualification may have to be upgraded.
TVA has concluded that the PAM equipment that will be installed and qualifted at plant restart will give the operator the information necessary to identify and mitigate DBEs and will be appropriately marked to indicate its importance.
The staff finds TVA's approach to identifying equipment within the scope of 10 CFR 50.49(b)(3) acceptable because it is in accordance with the requirements of that paragraph.
5.4 Conclusions On the basis of the above evaluation, the staff has reached the following con-clusions with regard to the qualification of electric equipment important to safety within the scope of 10 CFR 50.49:
(1) The Sequoyah electrical equipment environmental qualification program complies with the requirements of 10 CFR 50.49.
TVA VOL 2 SEC 5 5-9 01/09/87
s e
(2) TVA's proposed resolutions for each of the environmental qualification deficiencies identified in the staff's SER and the FRC TER are acceptable.
The staff's. findings regarding compliance with 10 CFR 50.49 rely on certain modifications / replacements that must be completed for the affe:ted equipment 4,
to be qualified.
In all cases, TVA is aware of what modifications or replace-ments are required. However, as a confirmatory action, before restart, TVA l will be required to certify that th. fyll a k; h ::: hn; i;;., m ;.t.d er f
sli Ett f ie leIwo rk. has b e e n c omj l* l^* d
- o Tk.rtn$ f w 'lI ver:fv ;
th+t f k e> <.,1r - s k e v< loee vs cc~f *N (19 resol tion or7 staff approv)1 of theqmain stefm line b7eak witp supfheat role se and ts of ect on the envirpnmental, qualification of equipment in the east an west,valvev9ultvaultrooms(A1,A2,A10,All),
/
I
'f(2)]allEQfiefdwork' (3) main stea vault; submergence review
/
(4) management review of EQ binders
/
l i
f (5) supplemental vendor information
/j (6) cable, load study I
l f
.(7) i,nside containment flood analysis for 5-minute operabil.ity
,i l
l f(8) erificatio of in #trument/accuracycalculation/
l l
i i
j I
I (9) inalizati n of t e EQ master 1 lst j
l The st ff will verify that tilese items have been omple ed.
TVA VOL 2 SEC 5 5-10 01/09/87