ML20235S438
| ML20235S438 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/05/1987 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| ULNRC-1640, NUDOCS 8710080500 | |
| Download: ML20235S438 (14) | |
Text
,
1 Union
,sEtscraic 33
\\
1901 Gratiot Street, St. Louis u
Donald F. 'Schnell k
Vce President October 5, 1987 1
U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
ULNRC-1640 DOCKET NUMBER 50-483 CALLAWAY PLANT RESPONSE TO NRC_ QUESTIONS ON MS_LB SUPERHEAT ANALYSIS
References:
- 1. NRC Request for Additional Information, T. W.
Alexion to D.
F.
Schnell, dated 9-10-87
- 2. WM 87-0253 dated 10-2-87
- 3. ULNRC-1473 dated 3-24-87
- 4. SLNRC 86-06 dated 4-4-86 The attachment addresses the questions transmitted via Reference 1.
These responses were developed jointly with Wolf Creek Nuclear Operating Corporation and reflect the standard plant design (see Reference 2).
If you have any questions on the attached responses, please contact us.
Very truly yours,
(
O_by -25 j
A Donald F.
Schnell b
GGY/ lad Attachment hO 00 p
o Mathng Addmss: P.O. Box 149, St. Louis, MO 63166
i k
i cc:
Gerald Charnoff,.Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.-
i Washington, D.C.
20037 Dr. J. O. Cermak CFA, Inc.
l 4 Professional Drive (Suite 110)
I Gaithersburg, MD 20879 i
W.
L. Forney Chief, Reactor Project Branch 1 l
U.S. Nuclear Regulatory Commission l
Region III
]
799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little l
Callaway Resident Office U.S.
Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 I
Tom Alexion (2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission t
Mail Stop 316 1
7920 Norfolk Avenue Bethesda, MD 20014 l
Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 l
l
____________________a
bcc:
D. Shafer/A160.761
/QA Record (CA-758)
Nuclear-Date
'DFS/ Chrono D.
F. Schnell J. E. Birk J. F. McLaughlin A. P. Neuhalfen R.
J. Schukai M.
A.
Stiller G.
L. Randolph i
R.
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Irwin H. Wuertenbaecher W.
R. Campbell A. C. Passwater l
R.
P. Wendling D.
E.
Shafer l
D. J. Walker O. Maynard (WCNOC)
R.
C. Slovic (Bechtel)
G56.37 (CA-460 )
Compliance (J. E. Davis)
NSRB (Sandra Auston)
G. G.
Yates E180.02 E z 10. 01 l
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ULNRC-1640 RESPONSE 'IO NRC QUESTIONS l
MAIN STEAM LINE BREAK SUPERHEAT ANALYSIS QUESTION 1:
For all instances where the qualification temperatures of various pieces of equipnent (e.g., Main Stean Pressure Transmitter, Main Steam Isolation Valve, etc.) may be exceeded as a result of a design basis accident and you have determined that alternate equipnent is available to accanplish the function of the failed equipnent, discuss the environmental qualification status of the alternate equipnent.
RESPONSE
In the Reference 1 evaluation of main steam line break (MSLB) superheat effects, the need to rely on alternate equignent is discussed with respect to two pst-accident indication functions, i.e.,
steam generator pressure monitoring and verification of steam generator isolation.
The alternate equipnent used to provide post-accident stean generator pressure indication consists of four pressure transmitters (one for each stean generator), AB-PT-01, 02, 03 and 04.
Because of their location outside of the main stean tunnel, these transmitters are not subjected to the harsh environmental conditions following a postulated MSm in the tunnel.
'Ihese transmitters are Class 1E and are fully qualified for the environmental conditions postulated for their locations in roans 1304 and 1305 of the Auxiliary Building.
Verification of steam generator isolation usirg alternate equignent may be required if valve position indication (limit switches and connected circuits) were to fail in the superheated MSLB environment.
Steam generator isolation involves not only the Main Stean Isolation Valves (MSIVs) but the Main Feedwater Isolation valves (MFIVs) and several J-601A, air-operated valves, such as the MSIV Bypass Valves and Stean Line Drain Valves.
'Ihe alternate equipnent, mentioned on page 7 of Reference 1, consists of steam generator level indication, steam generator pressure indication, auxiliary fee 3 water flow irxlication, reactor coolant temperature indication, and main steam flow indica-tion.
The equipment associated with these alternate indicatiry circuits is located outside of the main stean tunnel and, therefore, would rut be exposed to the MSLB superheat conditions. With the exception of the main stean flow indicatire circuits, all of the alternate equipnent is Clacs 1E and fully qualified for environmental conditions postulated at their respective locations.
'Ihe main steam I
flow transmitters are high quality, commercial grade l
equipnent and are powered fran buses supplied by standby power sources so that their availability is assured even in the event of a loss of offsite power.
ULNRC-1640 l
QUESTION 3a:
Is the criteria for using the alternate equignent contained in the plant emergency operating procedures?
RESPONSE
Specific steps for use of alternate indication, following a postulated MSLB with superheat in the main stean tunnel, are not currently included in plant operating procedures.
%e primary reason for this is that the review of this issue is ongoing, and incorporating the results of the review into procedures is considered premature.
- However, the lack of specific procedural guidance is not considered of concern because the plant operators are trained to use alternate indication in the course of accident mitigation and the alternate indication available for stean generator pressure and steam generator isolation verification are well known to the operators.
In response to a recent NRC inspection finding, Union Electric Company has incorporated a change into the emer-gency operating procedures at Callaway Plant addressing the use of AB-PT-01, 02, 03, and 04 for alternate steam gener-ator pressure monitoring.
QUESTION 2:
In your evaluation, it is stated that the Main Steam Isolation Valves and the Main Feedwater Isolgtion Valves are both qurlified to a temperature of 450 F; however, the appurtenances have various qualification temperatures.
Our review has found that somg of these qualification temperatures are as low as 300 F.
Note that the staff considers the qualification status of any piece of equip-ment to be based on its weak link.
Please explain why you consider this iten to be qualified to 450 F when some of its appurtenances are qualified tg temperatures less tgan 450 F (e.gd, Terminal Blocks 3g0 F, Limit Switch 343 F, Wiring 346 F, Terminal Lugs 352 and Conax Seals 420 F).
RESPONSE
We statenent regarding the 450 F qualification tempera-ture was not intended to be applied to all the actuator appurtenances.
We actuatgr was qualified by the vendor (Anchor-Darling) using 450 F stean.
Howaer, as identi-i fied in the Reference 1 evaluation, various appurtenances (limit switches, wiring, wiring lugs, etc.) were qualified under separate programs to different temperatures.
It is I
I noted ig more recent sutznittals (References 2 and 3), that the g50 F has itself been reduced to a lower temperature l
(328 F) because of the manner in which Anchor-Darling exposed the actuator to steam during testing.
he evalu-ation of equipnent performance during exposure to super-heated steam took into account the various temperatures to I
which the actuator and appurtenances had been qualified.
]
For example, Reference 1 identified the thin Stean Isola-i tion Valve (MSIV) actuator terminal blocks as a " weak i
link" camponent and required a special thermal lag analysis i
of the MSIV terminal blocks to be performed. - - _ _ _ _
ULNRC-1640 QUESTION 3:
Explain why the.(XLPE) ControgCable, identified in your submittal as qualified to 385 F, is expected to perform its function when its qualification temperature is exceeded.
RESPWSE:
'Ihis question is tot applicable to Callaway plant.
For 1
Wolf Creek Generating Station, credit is not taken for cable that is not qualified for its environmental cordi-tions.
The discussion in Reference 1 is intended to note that, because of the insulating material used, the cable would most likely perform acceptably during the short time that the qualification temperatures were exceeded.
'Ihe discussion goes on to explain and ultimately relies on the fact that, even if the cable failed such that the affected MSIV would not close, the effect on plant response would be no different than the FSAR Chapter 15 analysis of the MSIB event.
'Ihis is based on the plant design which inclu:les main steam lines in the tunnel designed and maintained as "superpipe" (i.e., a no break zone as defined in Beference
- 4) and on the NRC position, stated in Reference 5, that an additional single active failure need not be postulated if a break is assumed in a no break zone.
'Iherefore, the failure of one MSIV to close because of environmental effects results in identical mnditions (the uncontrolled blowdown of one steam generator) postulated in the FSAR accident analysis.
QUESTION 4:
In the sutmittal provided by letter dated April 1,1987,*
you have canpared various equipnent items to establish similarity. Althou]h all items may be similar as you have stated, you did not always provide sufficient information for a reviewer to reach that conclusion (e.g., on page 6 of 27 it is stated, in part, that a thermal lag curve was not specifically developed for a limit switch).
It was assumed that a limit switch housing thermal response would be similar to the response of the solenoid valve solenoid housing (Equipnent 1).
It is further stated that this assumption is appropriate because the thickness of the limit switch body is equal to the molded solenoid valve solenoid housing. You also referred the reader to a sketch.
Ebr Equipnent 1 (solenoid housing), you have provided sme detail information that is appropriate for comparison purposes such as the fabrication material of the housing, density, thermal conductivity, specific heat, thickness and a sketch.
However, similar information was not provided for the limit switch.
Consequently, for all instances where you have made canpar-isons similar to the above exanples, you must provide all information necessary to reach an independent conclusion (i.e., information such as that provided for Equipnent 1 in the above exanple).
l i
ULNRC-1640 l
[*%is date applies to the Wblf Creek Nuclear Operating Corporation subnittal; the corresponding Union Electric Ozupany subnittal is dated March 24, 1987.)
RESPWSE:
The sole instance of extrapolating calculated thermal lag paraneters frm one equipnent type to another is the use of a solenoid housing calculation to approximate a limit switch as identified in the response to question IF in References 2 ard 3.
Se requested data for comparing the solenoid housing to a limit switch are provided below:
Solenoid Limit Switch Housing
- Limit Switch Cover Housing EA170 EA180 Top Bottm Material stainless zine alloy bronze alloy stainless nickel-plated steel steel steel W ickness, 1/8 3/16**
3/16**
1/8 1/8 inches Density 488 446 54 0 488 490 lbn/ft Specific Heat, 0.11 0.091 0.082 0.11 0.11 l
Btu /lbn gF l
termal 9
64 15 9
26 Conductivity, Btq/hr-ft-F l
l Density, specific heat and thermal conductivity values are taken frm l
Principles of Heat Transfer, F. Kreith,1958, Appendix III for zine and bronze.
Approximate average thickness - refer to Figure 1.
Based on the above parameters, the lunped-capacity surface temperature response of the limit switches would be similar to the response of a solenoid valve solenoid housing.
QUESTION 5:
In accordance with IEEE Standard 323-1974, a margin of 15 P is required when qualifying for temperature in a harsh environment.
According to information provided for MSIV/MFIV control cable ang MSIV/MFIV wiring and lugs, g
margins of only 2 F ard 6F respectively, are indicat-ed. Discuss the rationale for your determination that this is acceptable.
RESPONSE
Se 15 F margin frm IEEE-323-1974 are appropriate for qualifying equipnent when environmental temperature cordi-l tions are known.
However, as in the case of the MSLB I l
ULNRC-1640 l
superheat issue, when a newly defined environmental condi.
tion, that exceeds the licensirg basis for the plant, is identified, the need to cmply with standard margin require-ments should not be a rigorous requirment. We evaluation of the MSIB superheat condition involves a dynanic situation
- j with time-dependent parameters. We goal of the analysis is to dmonstrate that the required equipnent will actuate to perform its safety function prior to exceedirg its qualifi-cation temperatures or, barring that, that environmentally-induced faults occurrirg either prior to or subsequent to actuation, will neither prevent the safety function frm being performed nor mislead plant operators.
Under these conditions, more credit should be given to the conservatism inherent in the analysis, such as:
i a.
%e Reference 6 Westinghouse mass / energy release calcu-lations do not contain factors that would reduce super-heat, e.g., froth, entrainment and compressibility.
b.
The Westinghouse calculations are based on a more conservative stean generator design (?bdel D4) than used in the SNUPPS plants (Fbdel F).
c.
We Westinghouse calculations use several conservative assumptions listed on page 3 of Reference 1, e.g., core decay heat, single failure of one safety injection train, steam generator level, etc.
d.
The temperature analysis assumed worst case, non-spatially varying conditions. throughout the main steam tunnel. No credit was taken for buoyancy effects in the tunnel atmosphere cooling the equipnent via natural circulation.
e.
The thermal lag calculations assumed heat transfer based on fluid velocities well in excess of those expected to occur in the vicinity of the equipment modelled.
f.
Margin requirements for equipnent picstulated to perform its function early in the event were discussed in Section 4.0 of Beference 1.
In the case of the margins identified in Question 5 for the MSIV/MPIV wiring and lug s, these camponents are located inside the terminal boxes on the MSIV/MFIV.
Weir thermal lag tmperature is based on a cne-dimensional analysis of the box itself (see discussion of its IF in References 2 and 3).
A more detailed two-dimensional analysis of these emponents would provide additional margin similar to the case of the MSIV/MFIV terminal blocks.
{ 1
-_ __ _________--________-_____-_ - ___ Q
ULWRC-1640 Based on the discussions in Reference 1 and in the response to Question 1-above, the failure of MSIV/MPIV limit switches would not result in a safety concern since alternate indic-ations-are available to asstge that valves are in their cafe positions; therefore,- the 2 P margin for the limit switches i
I is not a safety issue. In addition, it is noted that Westing-house Electric Corporation has qualified the NAMCO model EA180 limit switcheg used on the MSIVs and MFIVs to a temperature in excess of 400 F.
Pagarding the margins for MSIV/MFIV control cable discussed in Question 5, all MSIV/MFIV control cable meets the margin recommended in IEEE-323-1974 with the exception of the cable for one MSIV at iclf Creek Generating Station.
The implica-tions of this were evaluated in Reference 1 and further discussed in the response to Question 3 above.
QUESTION 6:
The analysis conducted for main stean line break with super--
heat indicated that the qualification temperatures of four itens of equipnent will be exceeded, and an additional two items (identified in Question 5 above) does not need the margin requirement of IEEE-323-1974.
'Ihese six items are identified in Table 3.4 of your submittal as:
1.
Main Stean Pressure Transmitter Instrtsnent Cable 2.
MSIV/MFIV Wiring and Lugs 3.
MSIV/MFIV Control Cable 4.
MSIV/MFIV Limit Switch 5.
MSIV/MFIV Limit Switch Instrtxnent Cable 6.
J-601A Control Cable Discuss the consequences of the simultaneous failure of all six itens.
RESPCNSE:
'Ihe main stean pressure transmitter instrument cable carries the low steamline pressure signal from the 12 pressure transmitters (3 per steam line) to initiate a Steam Line Isolation Signal (SLIS).
The consequences of failure of these cables in the superheated MSIB environment has been discussed, in Section 3.3. A of Reference 1, for the SLIS function as well as the post-accident stean generator pressure monitoring function.
As noted in Reference 1, the SLIS l
function would not be adversely affected by the cable failure modes.
'Ihe longer term stean generator pressure monitoring function was also a3 dressed in Reference 1 and in the response to Question 1 above.
ULNRC-1640 The MSIV actuators must receive an electrical signal to close the MSIVs, whereas the MFIV actuators fail closed on a loss of electrical signal.
Therefore, the following discus-sion will focus on the MSIV actuators.
We signal required to close the MSIVs is transmitted via MSIV control cable and MSIV wiring and lugs to the MSIV solenoid valves.
W ere are two, redundant electro-pneunatic-hydraulic actuators on each MSIV; one receives a signal fran safety train A (separation group 1) and the other, from safety train B (separation group 4).
Actuation of solenoid valves on either of the redundant actuators (designated " active" and " standby") will result in closure of the MSIV.
The active solenoids and terminal boxes (containing the MSIV wiring and lugs) are
' located on diametrically opposite sides of the actuator (see Figure 2). %erefore, the assumption regarding fluid velocity used in thermal lag heat transfer calculations, discussed in the response to Question 5 above, contains additional conser-vatism; because it is unlikely that the same high fluid velocity would be present on opposite sides of the actuator.
Mditional discussion of temperature margin for MSIV closure I
circuit components was provided in the response to Question 5.
Based on that information, the MSIV closure circuits are expected to perform acceptably to close the valves (with the exception of the singular MSIV addressed in Question 3 above at Hblf Creek whose failure to close does rxat result in an unanalyzed con:lition). After the MSIVs and MFIVs are closed, environmentally induced failures of the actuators and/or appurtenances and control cable will not result in the valves reopening.
We loss of valve position indication resulting from limit switch or limit switch cable failures for each MSIV/MFIV or J-601A valve would not result in valve repositioning nor cause the plant operating staff to take any actions adverse to safety because the operators would not be expected to take actions based on those failures other than to verify valve position.
If valve position needed to be verified, the alternate methods previously discussed in Question 1 would be available to the operators.
We postulated failure of J-601A control cable is addressed via f ailure modes and effects analysis in Reference 1, Sections 3.3.C, E, and F.
The analysis concluded that control circuit failures would either cause the valve to actuate to its safe position or not prevent a safety signal fran actuating the valve to its safe position.
In addition, once actuated the valve would not repasition if an environ-mentally-induced control circuit failure occurred.
Based on the above discussion, the simultaneous failure of the equipnent identified in NRC Question 6, with the excep-tion of the MSIV closure circuit components, would not pose
(
any significant difficulty for the operators in controlling
_7_
ULNRC-1640 the plant and mitigating the MSIB.
In addition, the t sper-ature margin applicable to the MSIV-closure circuit canpo-j nents could be increased throtgh additional analysis with less conservative assumptions.
However, the additional information regarding margins in the above discussion and in the response to Question 5 provides adequate assurance that the equipnent required to close the MSIVs will perform its safety function.
l 1
I l
1 1b17-27 l 1 I
I E_______________________________-.___
ULNRC-1640 1
REFERENCES:
1' l.
" Evaluation of Environmental Qualification of Equipment Cbnsiderirg Superheat Effects of High Energy Line Breaks for l
Callaway Plant and Wlf Creek Generating Station", forwarded i
by SNUPPS letter SLNRC 86-06, dated 4/4/86.
2.
Union Electric Company letter (D. Schnell) to NRC, UIFRC-1473, dated 3/24/87.
3.
Nblf Creek Nuclear Operating Corp. letter (B. Withers) to NRC WM 87-107, dated 4/1/87.
4.
NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, 7/81 (Branch i
Technical Position MEB 3-1).
5.
NRC Memorandun H. Denton, ONRR to V. Stello, DEDROGR, dated 4/29/85:
Position on a MSIB in Superpipe Concurrent with a Single Active Failure.
6.
WCAP-10961-P, Steamline Break Mass / Energy Releases for Equip-ment Environmental Qualification Outside Contairrnent, October, 1985.
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