ML20246K488
| ML20246K488 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/28/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89327, NUDOCS 8909050488 | |
| Download: ML20246K488 (23) | |
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Log # TXX-89327-File # 10010 1
C 918' Ref. # 10CFR50.34(b) 1UELECTRIC '
August 28, 1989 DENS?$eNo V. S. Nuclear Regulatory Commission Attn: Document-Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PCAK STEAM ELECTRIC' STATION (CPSES)
DOCKET NOS, 50-445 and 50-446 ADVANCE FSAR SUBMITTAL: UPDATED RESPONSE TO 0022.2 CONCERNING CONTAINMENT REANALYSIS
- Gentlem.tn:
Amendment 76 to the CPSES FSAR was transmitted-to the NRC in TXX-89201, dated May 1, 1989. As part of that amendment, the TU Electric response to NRC Ouestion 022.2 was updated to make it consistent with previously transmitted FSAR changes (Amendment 69) resulting from the containment reanalysis using the LOCTIC computer code. A portion of the changes for the update to the response to 0022.2 wss not included in Amendment 76.
The enclosure to this letter provides these changes, along with related supporting documentation.
These changes will be included in a future FSAR avendment.
In order to facilitate NRC staff review of these changes, the enclosure is organized as follows:
1.
Draft revised FSAR pages, with changed portions indicated by a bar in the margin, as they are to appear in a future amendment (additional pages immediately preceding and/or following the revised pages are provided if needed to understand the change).
2.
A line-by-line description / justification of each item revised.
3.
A copy of related SER/SSER sections.
4.
An index page containing the title of " bullets" which consolidate and categorize similar individual changes by subject and related SER/SSER section.
4 8909050488 890EENB PDR ADOCK 0"KX)D445
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400 Nonh Olive Street LB 81 Dallas, Texas 75201 i
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' August 28, 1989 Page'2 of 2 5.
A discussion of each " bullet" which includes:
The Line-by-line description / justification for each item related to the " bullet" which has been screened as a group 1 or 2. item or a group 3 or 4 item which impacts the.
existing SER/SSER's.
(The discussion of these groups is contained in TV Electric letter TXX-88467,, dated June 1, 1988)
The bold / overstrike version of.the revised FSAR pages referenced by the description / justification for each item identified above. The bold / overstrike version facilitates review of the revisions by highlighting each addition of new text in bold type font and.overstriking with a slash
(/) the portion of the' text that is deleted.
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Sincerely,
/
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William J. Cahill,.Jr.
BSD/bsd.
Enclosure c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)
i Enclosure to TXX-89327 August 28, 1989 Page 1 of 21 Advance' FSAR Chat.ge to Response for Question 022.2 and Supporting Documentation Item 1 Draft Revised FSAR pages pp. 2 - 4 Item 2 Line-by-line Description / Justification pp. 5 - 7 for each FSAR Change Item Item 3 Related SER/SSER Pages pp. 8 - 15 Item 4 Index page of bullet title (s) p.
16 Item 5 Discussion of each bullet pp. 17 - 21
Encrosura to TXX-89327-CPSES/FSAR~
Paga 2 of,21 pressure setpoint of HI-3-(20 psig) was reached for large breaks.
For small breaks 76 the spray. delay time is 38 seconds.
f.
Identification of most severe' environment
'l _5 Among the MSLB's analyzed, the 0.908.ft2
'S split rupture at 70-percent power. results in the maximum Containment temperature; The Containment vapor temperature for this break is shown-in Figure 6.2.1-15.
s 2.
. Safety Related Component' Thermal Analysis 5'
The peak containment vapor temperature for the 76 design basis MSLB was calculated to be 3450F.
Component thermal analyses'are required'only if the 5-environmental qualific6 tion test conditions are less than those calculsted from the Containment pressure-temperature transient response analysis, a.
Transmitters 5
All transmitters located inside containment DRAFT and required to operate for a design basis MSLB to mitigate the accident consequences, are qualified by testing or by a combination of testing and thermal analysis in accordance with IEEE 323-1974 requirements.
b.
Electrical cables l5 The cables are qualified by testing / analysis DRAFT to a maximum temperature of 3450F, ~The
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022-16
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CPSES/FSAR I
Encresure to TXX-89327 Page 3 of,21 qualification meth:d is in acc:rdance tith DRAFT IEEE 383-1974 and IEEE 323-1974.
5
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c.
Containment electrical penetration DRAFT The Containment electrical penetrations and DRAFT their header plate assemblies are qualified by testing to temperatures exceeding 3450F.
The qualification method is in accordance with IEEE 317-1976 and IEEE 323-1974.
j d.
Valves / Valve Operators DRAFT The valves located inside containment consist 5
of two groups:
(1)
Target Rock and ASCO solenoid valves DRAFT are qualified by testing to temperatures above 3450F, and 022-16
U Encl'osura to TXX-89327' CPSES/FSAR Pag 2 4 of.21 (ii)
Valcor solenoid valves are qualified by DRAFT testing / analysis to a maximum temperature of 3460F.
The Limitorque operators of all valves located DRAFT inside containment are qualified by testing to a maximum temperature significantly above 3450F, The qualification method for valves / valve operators is in accordance with IEEE 323-1974.
DRAFT.
3.
Evaluation of Environmental Qualification 5
The test temperature profiles used for 5
environmental qualification are included in the Equipment Qualification Documentation referenced in Section 3.11.
In the case of electrical cables, containment 5
electrical penetration assemblies and valves, the peak temperatures are maintained for periods well in excess of 10 minutes.
022-Ih
- Encrosura to TXX-89327
-0ETAILED DESCRIPTION Page-1 Page 5 of.21 J
FSAR Page.
(as amended)
Group Description 0&R 022-16 2
Revises maximum qualification temperature for cable inside containment.
Revision:
i Qualification temperature revised from 346 degrees F to 345 degrees F.
The qualification is still consistent with the previously revised (Amendment 76) peak containment vapor. temperature of 345 degrees F.
FSAR Change Request Number: 89-308.1 Related SSER Section: SSER6 3.11 SER/SSER Impact: No Q&R 022-16 3
Revises response to describe finalized qualification plan for containment transmitters, j
Update:
Revised response part B.2.a.to state that all transmitters located insidc containment and required to-operate for a design basis MSLB are qualified by testing / analysis in accordance with IEEE 323-1974.
This change provides additional information concerning the finalized qualification plan for transmitters.
FSAR Change Request Number: 89-308.2.
Related SSER Section: SSER6 3.11 SER/SSER Impact: No Q&R 022-16, 17 2
Deletes statement that no thermal analysis is required from response parts B.2.a. B.2.b and B.2.c.
Revision:
Deletes wording indicating that no thermal analysis is required from question response parts B.2.a. B.2.b and B.2.c.
Qualification of electrical cables, containment electrical penetration assemblies, and valves / valve operators are performed in accordance with the requirements of IEEE 323-1974. Where appropriate, thermal analyses are performed.
FSAR Change Request Number: 89-308.3 Related SSER Section: SSER6 3.11 SER/SSER Impact: No 0&R 022-16 2
Adds word " analysis" to discussion of cable I
qualification.
Revision:
Adds the word " analysis" to indicate that cables inside containment are qualified by testing and/or analysis. Where analysis is required, it is performed in accordance with IEEE 323-1974.
FSAR Change Request Number: 89-308.4 Related SSER Section: SSER6 3.11 SER/SSER Impact: No j
- Encrosura to TXX-89327 CPSES FSAR AMENDHENT 77 DETAILED DESCRIPTION Pag 2 2 Page 6 of.21 i
FSAR Page j
(as amended)
Group Description J
l O&R 022-17 4
Deletes the word " assemblies" from response part 1
I B.2.c.
Clarification:
l Deletes the word " assemblies" from response part B.2.c to clarify that the entire penetrations are qualified.
FSAR Change Request Number: 89-308.5 Related SSER Section: SSER6 3.11 SER/ T,SER Impact: No Q&R 022-17 3
Revises discussion of containment electrical penetrations to provide specific information an qualification temperatures.
Revision:
Revises response to part B.2.c. to note the increase in containment electrical penetrations and header plate assemblies maximum qualification test temperature from 340 to in excess of 345 degrees F.
FSAR Change Request Number: 89-308.6 Related SSER Section: SSER6 3.11 SER/SSER Impact: Yes SSER 6 Section 3.11.3 discusses old temperatures.
0&R 022-17. 18 3
Deletes discussion on thermal analysis for valve qualification.
Revision:
Deletes discussior, on thermal analysis for valve qualification to be consistent with addition of current valve qualification data from testing. All valve qualification tests were performed in excess of conditions determined from containment pressure-temperature response analysis and thus no thermal analysis is required for valves.
FSAR Change Request Number: 89-308.8 Related SSER Section: SSER6 3.11 l
SER/SSER Impact: Yes SSER 6. Section 3.11.3 contains old qualification data.
O&R 022-17 3
Adds maximum qualification temperature for Limitorque operators.
Addition:
Indicates that the maximum qualification temperature.
by test. for Limitorque operators is well above the i
peak containment vapor temperature for a design basis MSLB.
FSAR Change Request Number: 89-308.9 Related SSER Section: SSER6 3.11 SER/SSER Impact: Yes SSER 6. Section 3.11 0 contains old qualification data.
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b Encibsura to TXX-89327 CPSES FSAR AMENDMENT 77 DETAILED DESCRIPTION Page 3 Pag] 7 cf,21_
FSAR Page l
1 (as amended)
Group Description O&R 022-17 3
See Page No(s):18 Provides valve specific-information to response part B.2.d.
Update:
Revises response part B.2.d to provide valve specific-information, as follows:
(1) Target Rock and ASCO solenoid valves qualification test temperatures exceed the maximum postulated temperature envelope inside containment (i.e. 345 degrees F), and (ii) the Valcor solenoid valves maximum qualification test / analysis temperature also exceeds 345 degrees F.
FSAR Change Request Number: 89-308.7 Related SSER Section: SSER6 3.11 SER/SSER Impact: Yes SSER 6 Section 3.11.3 has old values for valves.
F
_ Encfosure to TXX-89327 7';Page 8 of.21 which the analysis shows that the component or structure is not capable of withstanding the load, the applicant will provide the necessary protection.
Protection will consist of either relocating the target or installing jet shields or barriers to protect the target.
The staff finds these provisions to be acceptable.
3.6.2.4 Conclusions The protection afforded essential equipment at Comanche Peak against'the effects of pipe breaks is described in Section 3.6B of the FSAR (Amendment 45) and in the applicant's letters dated September 13, 1983, and January 5, 1984 Based on its evaluation of this material, the staff concludes that the plant design for protection against postulated piping failure in fluid systems outside containment is in compliance with the requirements of GDC 4 and the guidelines of BTP ASB 3-1 and is, therefore,' acceptable.
The design of the plant for providing protection against postulated piping failures meets the acceptance criteria of SRP Section 3.6.1.
3.11 Environmental Qualification of Electric Equipment Important to Safety and Safety-Related Mechanical Equipment 3.11.1 Introduction Equipment that is used to perform a necessary safety function must be demon-strated to be 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 embodied in 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 containment.
More detailed requirements and guidance relating to the methods and procedures for demonstrating this capability for electrical equipment have been set forth in 10 CFR 50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants"; NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," which supplements IEEE Standard 323; and various NRC regulatory guides and industry standards.
3.11.2 Background NUREG-0588 was issued in December 1979 to promote a more orderly and systematic implementation of equipment qualification programs by industry and to provide guidance to the NRC staff for its use in ongoing licensing reviews.
The positions contained in that report provide guidance on (1) how to establish environmental service conditions, (2) how to select methods which are con-sidered appropriate for qualifying equipment in different a.reas of the plant, and (3) other areas such as margin, aging, and documentation.
In February 1980, the NRC requested certain near-term operating license (OL) applicants to I
review and evaluate the environmental qualification documentation for each l-item of safety-related electrical equipment and to identify the degree to which their qualification programs complied with the staff positions discussed I
in NUREG-0588.
IE Bulletin 79-01B, " Environment Qualification of Class IE Equipment " which was issued January 14, 1980, and its supplements dated February 29, September 30, Comanche Peak SSER 6 3-4
Encicsure to TXX-89327
' Pag] 9 of.21 and October 24, 1980, established environmental qualification requiremea*s fer operating reactors.
This bulletin and its supplements were provided ta CL applicants for consideration in their reviews.
A final rule on environmental qualification of electrical equipment important to safety for nuclear power plants became effective on February 22, 1983.
This rule (10 CFR 50.49) specifies the requirements to be met for demon-strating the environmental qualification of electrical equipment important to the safety located in a harsh environment.
In accordance with 10 CFR 50.49, electrical equipment for Comanche Peak may be qualified in accordance with the acceptance criteria specified in Category I of NUREG-0588.
The qualification requirements for mechanical equipment are principally contained in Appendices A and 8 of 10 CFR 50.
The qualification methods defined in NUREG-0588 can also be applied to mechanical equipment.
To document the degree to which the environmental qualification program complies with the NRC environmental qualification requirements and criteria, the applicant provided equipment qualification information by letters dated January 24, 1983, February 3, 23, and 24,1983, May 5,1983 June 7 and 28 1983, September 13, 1983, January 5,1984, February 7,1984. June 26 and 29, 1984, July 20, 1984, and August 10, 21, and 23, 1984.
The staff has reviewed the adequacy of the Comanche Peak environmental quali-fication program for electrical equipment important to safety as defined in 10 CFR 50.49 and for safety-related mechanical equipment.
The scope of this report includes an evaluation of (1) the completeness of the list of systems and equipment to be qualified, (2) the criteria they must meet, (3) the environ-ments in which they must function, and (4) the qualification documentation for the equipment.
It is limited to electrical equipment important to safety within the scope of 10 CFR 50.49 and safety-related mechanical equipment.
3.11.3 Staff Evaluation The staff evaluation included an onsite examination of equipment, audits of qualification documentation, and a review of the applicant's submittels for completeness and acceptability of systems and components, qualification methods, and accident environments.
The criteria described in SRP Section 3.11, Rev. 2 (regarding NUREG-0588 Category I), and the requirements in 10 CFR 50.49 form the bases for the staff evaluation.
The staff performed an audit of the applicant's qualification documentation and installed electrical equipment on August 30 through September 3, 1983.
The audit consisted of a review of 19 files containing information regarding the equipment qualification.
The staff's findings from the audit are discussed in detail in Section 3.11.3.4 of this supplement.
The staff's evaluation of the mechanical equipment qualification program is discussed in Section 3.11.4.2.
3.11.3.1 Completeness of Equipment Important to Safety l
The three categories of electrical equipment that must be qualified in accordance with the provisions of 10 CFR 50.49 are j
Comanche Peak SSER 6 3-5
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Page 10 of 21 t
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(1). safety-related electric.al equipment (i.e., equipment relied on to remain functional during design basis events)
(2) nonsafety-related electrical equipment whose failure under the postulated environment'l conditions could prevent. satisfactory accomplishment of the safety functions by the safety-related equipment (3) certain postaccident monitoring equipment ~(RG 1.97, Rev. 2, Category 1 and 2 postaccident monitoring equipment)
A list of equipment that is classified as Class IE and is included in the qualification program is provided in Comanche Peak FSAR Table 17A-1 and is
' designated as Class IE in that table.
Table 3.1 of this report lists the systems identified and their safety functions, as well as mechanical systems that have no Class 1E corrponents and their function.
To address conformance with 10 CFR 50.49(b)(2) of the rule concerning nonsafety related equipment whose failure under postulated accident conditions could prevent the satisfactory accomplishment of safety funtions, the appli-cant referred to staff reviews of IE Information Notice 79-22, " Qualification of Control Systems," and RG 1.75, " Physical Independence of Electric Systems."
The staff review and evaluation of the IE Information Notice 79-22 response is described in Section 7.7.2 of NUREG-0843.
No design changes or additional equipment qualification are necessary to ensure that HELBs do not cause control system failures to complicate events beyond the FSAR analysis.
Section 8.4.5 of the Comanche Peak SER describes the applicant's conformance with the guidelines in RG 1.75.
On this basis, the staff concludes that the applicant's conformance to 10 CFR 50.49 (b)(2) is acceptable.
The applicant has also addressed, in FSAR Section 7.5, compliance with RG 1.97, Revision 2.
However, the applicant has taken exception to the qualification requirements for certain' Category I and II equipment.
The staff wil1 determine the acceptability of these exceptions as part of its review for conformance with RG 1.97.
inis review may result in the addition of equipment to the environmental qualification program.
The applicant has also identified the equipment required by NUREG-0737,
" Clarification of TMI Action Plan Requirement 1," and their qualification status has been established.
3.11.3.2 Qualification Methods 3.11.3.2.1 Electrical Equipment in a Harsh Environment Detailed procedures for qualifying safety-related electrical equipment ir a j
harsh environment are defined in NUREG-0588.
The criteria in this report are also applicable to other equipment important to safety defined in 10 CFR 50.49.
Type testing of ecuipment in a sequence consisting of pre-aging (thermal, radiation, and mechanical), seismic and dynamic loading, and exposure to LOCA/HELB conditions (where applicable) is the preferred method of qualifi-cation.
However, in a number of cases, the applicant has extrapolated partial test data to establish equipment qualification.
1 Comanche Peak SSER 6 3-6 i
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i icl'osure to TXX-89327 sge 11 cf. 21 3.11.3.2.2 Safety-Related Mechanical Equipment in a Harsh Environment
.o remar Although there are no detailed requirements for mechanical equipment, GC"
- Dostulat and 4 and Appendix B to 10 CFR 50, " Quality Assurance Criteria for Nuclear ant of t Power Plants and Fuel Reprocessing Plants" (Sections III and XVII), contain the following requirements related to equipment qualification:
?gsry 1 Components shall be designed to be compatible with the postulated environ-(1) mental conditions, including those associated with LOCAs.
(2) Measures shall be established for the selection and review for suitability
. the i
of application of materials, parts, and equipment that are essential to
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safety-related functions.
systems (3) Design control measures shall be established for verifying the adequacy of design.
(4) Equipment qualification records shall be maintained and shall include the
[",d th0' results of tests and materials analyses.
'ficatio' The staff review is concentrated on materials which are sensitive to environ-
?ystems.
mental effects; for example, seals, gaskets, lubricants, fluids for hydraulic
'P2
- cas"8' systems, and diaphragms.
The staf f's findings on qualification docunientation are discussed in section 3.11.4.2.
o, 3.11.3.3 Service Conditions mmance at the NUREG-0588 defines the methods to be used for determining the environmental conditions associated with LOCAs or HELBs inside or outside containment.
The review and evaluation of the adequacy of these environmental conditions are RG 1','
described below.
The staff has reviewed the qualification documentation to ensure that the qualification conditions envelop the conditions established by
},at b"i the applicant.
h8"C' 3.11.3.3.1 Temperature, Pressure, and Humidity Conditions Inside Containment The applicant provided the LOCA/ main steam line break (MSLB) profiles used for equipment qualification.
The peak values resulting from these profiles are as in.
follows:
Maximum Maximum Temperature, 'F Pr' essure, psia Humidity, %
LOCA 268 48.1 100 MSLB 334 37.5 100 The staff has reviewed these profiles and finds them acceptabit for use in are
' R 50'g equipment qualification; i.e., there is reasonable assurance that the actual j'
pressures and temperatures will not exceed these profiles anywhere within the
'3 specified environmental zone (except in the break zone).
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)artia Cnmanche Peak SSER 6 3-7 i
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EncTosure to TXX-89327 Page 12 of 21 i
3.11.3.3.2 Temperature, Pressure, and Humidity Conditions Outside the Primary Containment The applicant has provided the temperature, pressure and humidity conditions associated with HELBs outside containment.
The criteria used to cefine the location of HELBs are described in FSAR Section 3.6.
The following areas outside containment are subjected to a harsh environment following an HELB:
(1) safeguards building (2) electrical and controls building (3) auxiliary building (4) turbine building The applicant has established that the postulated environmental conditions associated with moderate-energy line breaks (MELBs) are enveloped by the conditions associated with HELBs.
The HELB conditions are described in Section 3.6 of the FSAR, and the staff's review findings are given in SER Section 3.6.
3.11.3.3.3 Submergence The maximum submergence levels have been established by the applicant in the environmental qualification program.
The inside containment flood level established by the applicant is elevation (el) 817 ft.
The applicant has provided evaluations for any equipment located below the submergence level.
These evaluations, based on operability requirements and failure mode effects analysis (FMEA), have been reviewed and approved by the staff.
The applicant has established flood levels outside containment and has relocated safety-related equipment above these levels.
3.11.3.3.4 Chemical Spray Chemical spray is available for containment heat removal following a design-basis accident.
The specified composition of the spray is 2300 ppm H B0 3 3 buffered with NaOH to a pH of 8.6 to 10.0.
Equipment inside containment was reviewed for qualification under the above conditions.
3.11.3.3.5 Aging The degrading NUREG-0588, Category I, outlines the aging program requirements.
influences of temperature, radiation, vibration and mechanical stress 2s should Any justification for excluding be considered and included in the aging program.
pre-aging of equipment in type testing should be established based on equipment This requires design and application, or on state-of-the-art aging techniques.
In addition, the establishment for a qualified life for each equipment item.
a maintenance / surveillance program should be implemented to identify and prevent significant age-related degradation in electrical and mechanical equipment.
l The applicant has committed to follow the recommendations in RG 1.33, Revision 1,
" Quality Assurance Program Requirements (Operation)," which endorses American National Standard ANSI N18.7-1972, " Administrative Controls for Nuclear Power This standard defines the scope and content for a maintenance /
Plants."
Comanche Peak SSER 6 3-8
Enciesura^to TXX-89327
^
Page:13 of. 21' surveillance program for safety-related equipment.
or detecting age related degradation in safety grade equipment are specifi c and include the following:
(1)-
Development of a maintenance program to maintain safety-related equipment at the quality required for it to perform its intended function.
(2)
Evaluation of causes of equipment failures and review of experience with failed equipment and similar components to determine whether a replacement component of the same type can be expected to perform its function reliably.
(3)
Inspection and performance testing to ensure an appropriate quality level.
(4) Development of preventive maintenance schedules that describe the frequency and type of maintenance to be performed.
A preliminary schedule should be developed early in plant life and it should be refined and changed as experience is gained with the equipment.
(5)
Surveillance testing related to the results of reliability analyses, frequency and type of service, or age of the item or system, as appropriate.
These guidelines apply to equipment located in both harsh;and mild environ-The applicant has described a program that incorporates the preceding ments.
guidelines, and has stated that this program has been implemented.
3.11.3.3.6 Radiation (Inside and Outside Containment)
The applicant has provided values for the radiation levels postulated to exist following a LOCA.
The application and methodology employed to determine these values were presented to the applicant in NUREG-0588 and NUREG-0737.
The staff review determined that the values to which equipment was qualified enveloped the requirements identified by the applicant.
The value specified for use in equipment qualification in the containment is 1.92 x 108 rads gamma plus beta.
In the auxiliary and safeguard buildings, a value of 8.11 x IOS rads gamma has been used in areas with recirculating-fluid lines.
These values are acceptable for use in the qualification of equipment.
3.11.3.4 Environmental Qualification Audit The staff conducted an audit of the applicant's qualification documentation and installed equipment on August 30 through September 3, 1983.
There were 19 items of equipment that were reviewed if the test data and analysis in the files supported the qualification status determined by the applicant.
l-i The staff's findings during the audit were documented in a memorandum from H. C. Garg, NRC, to Z. R. Rosztoczy, NRC, dated October 14, 1982.
Since then the applicant has resolved all open items, unless otherwise noted elsewhere in the SER.
Comanche Peak SSER 6 3-9 A
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- Encl'osuri to.TXX-89327 Page 14.cf. 21-
-- 3.11. 3. 5 ~ Outstanding Equipment t
For safety-related items not having. complete qualification documentation. the applicant has provided commitments f r corrective action and senedules for completion of documentation.
For ". ems identified to date that will not have full qualification before an operating license is. issued, analyses have been performed in accordance with 10 CFR 50.49(i) to ensure that the plant can be operated safely pending completion of environmental qualification, These analyses' have been submitted for. consideration. The :taff has reviewed the justifications for interim operation and has concluded that reasonable assur-ante has been provided that Comanche Peak can be operated safely pending completion of environmental qualification.
3.11.4 Qualification of Equipment The following subsections present the staff's assessment of safety-related electrical equipment based on the applicant's submittal, audits of documen-tation at the plant site, information in the NRC Equipment Qualification Data Bank, and previous staff evaluations of equipment in other plants.
3.11.4.1 Electrical Equipment Important to Safety The staff has separated ti.
electrical equipment in a harsh environment into three categories:
(1) egr pment requiring replacement before plant startup, (2) equipment requiring additional qualificatica information or corrective action, and (3) equipment considered acceptable.
An appendix listing equipment ~
in each of these categories is provided.
3.11.4.1.1 Equipment Requiring Replacement Before Plant Startup There is no equipment in this category for Comanche Peak.
'3.11.4.1.2 Equipment Requiring Additional Information and/or Corrective Action The staff has reviewed the equipment identified in Table 3.2.
The equipment deficier.cies have been determined on the basis of all the information avail-able to the staff, and do not necessarily mean the equipment is % qualified.
The applicant has submitted justifications for interim operation for some of the equipment listed in Table 3.2.
The applicant must submit analys es fu the remaining equipment on this table, or confirm that the equipment has been qualified before fuel loading. This item is being added as a confirmatory issue in Section 1.8 of this supplement.
l 3.11.4.1.-
Equipment Considered Acceptable On the basis of the staff's review, the items in Table 3.3 have been determined to be acceptable.
j 3.11.4.2 Safety-Related Mechanical Equipment The staff selected three items from the applicant's master parts list of safety-related mechanical equipment from the master list of equipment to deter-mine if the program described in the environmental qualification submittal
! l Comanche Peak SSER 6 3-10 l sL l
.EncTcsure ta TXX-89327 Paga 15 cf,21 was satisfactorily implemented.
Purchase specifications, drawings, materist analyses and' partial test data were provided by the applicant to demonstrate that nonmetallic age-sensitive components would withstand the conditions associated with the design-basis accidents (DBAs).
Although review of this matertai snowed satisfactory evaluations of the three safety-related mechanical equipment items submitted, the applicant must perform a review and evaluation of all remaining safety-related mechanical equipment located in harsh environment areas and provide the results of the review, the corrective actions identified, and justifications for interim operation fer any mechanical equipment whose qualification cannot be established before power ascension above 5% full power.
The applicant has committed to perform this review and evaluation.
a.11. 5 Conclusions The staff has reviewed and evaluated the Comanche Peak program for the envi-ronmental qualification of electrical and mechanical equipment.
This review has included the systems selected for qualification, the environmental condi-tions resulting from design-basis accidents, the methods used for qualifica-tion and the documentation for specific items of equipment.
Based on these considerations, the staff concludes that satisfactory completion of the confirmatory item discussed in Section 3.11.4.1.2 must be documented before fuel loading.
In addition, the staff's review has determined that the following license conditions must be imposed:
(1) All electrical equipment within the scope of 10 CFR 50.49 must be environmentally qualified by the deadline in that rule.
(2) Before power ascension above 5% of full power, the applicant must complete the safety related mechanical equipment qualification program for all safety-related mechancial equipment located in a harsh environ-ment and establish qualification or submit a justification for interim operation for each equipment item.
Considering the confirmatory item and license conditions above, the staff concludes that Comanche Peak is in compliance with the requirements of 10 CFR 50.49 and relevant parts of GDC 1 and 4 of Appendix A; Sections III, XI, and l
XVII of Appendix B, 10 CFR 50; and the criteria specified in NUREG-0588.
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a Comanche Peak 55ER 6 3-11 1
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h; Ar F.ncTesure to$TXX-89327 lL :o Page 16 of,21 -
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l3.11 Environmental Qualification of Safety-Related Electrical Ecuioment l
SPLB.-
l27. The FSAR has revised the response to 0022.2 to concerning the qualification of safety-related equipment'inside' containment..
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- Encfosure'to:TXX-89327
-DETAILED DESCRIPTION
- .Page 171Gf 21'
,1 lFSAR Page "
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fas amended)
Grous Description.
~0&R 022-16' 2
Adds word " analysis" to-discussion of cable i
2:
. i'
. qualification.
Revision:
Adds the word " analysis" to indicate that cables inside containment are qualified by testing and/or analysis. Where analysis is required, it is performeds in accordance with IEEE 323-1974.
FSAR Chenge Request Number:-89-308.4 Related SSER Section: SSER6 3.11 SER/SSER Impact: No 0&R 022-16' 2
Revises maximum qualification temperature for. cable
.inside containment.
Revision:
Qualification temperature revised from 346 degreer F to 345 degrees F.
The qualification is still consistent with the previously revised (Amendment.76) peak containment vapor temperature of 345 degrams F.
FSAR Change Request Number: 89-308.1 Related SSER Section: SSER6 3.11 SER/SSER Impact: No
' 0&R 022-16. 17 2
Deletes statement that no. thermal analysis is regoired -
from response parts B.2.a, B.2.b and B.2.c.
Revision:
Deletes wording indicating that no thermal analysis,is -
required 'from question response parts B.2.a, B.2.6 and 8.2.c.
Qualification of electrical cables, containment electrical penetration assemblies, and valves / valve.
operators are performed in accordance with the requirements of IEEE 323/1974. Where appropriate, thermal analyses are performed.
FSAR Change Request Number: 89-308.3 Related SSER Section: SSER6 3.11 SER/SSER Impact: No 1
Q&R 022-17 3
Adds maximum qualification temperature for Limitorque L
operators.
Addition:
Indicates that the maximum qualification temperature.
by test, for Limitorque operators is well above the peak containment vapor temperature for a design basis MSLB.
FSAR Change Request Number: 89-308.9 Related SSER Section: SSER6 3.11 SER/SSER Impact: Yes SSER 6. Section 3.11.3 contains old qualification data.
~~
L
- Enc)"osure.to TXX-89327 DETAILED DESCRIPTION Page 18 of,21 3
FSAR Page (as amended)
Group Description Q&R 022-17, 18 3
Deletes discussion on thermal analysis for valve qualification.
Revision:
Deletes discussion on thermal analysis for valve qualification to be consistent with addition of current valve qualification data from testing. AIT valve qualification tests were performed in excess of conditions determined from containment pressure-temperature response analysis and thus no thermal analysis is required for valves.
FSAR' Change Request Number: 89-308.8 Related.SSER Section: SSER6 3.11 SER/SSER Impact: Yes SSER 6. Section 3.11.3 contains old qualification data.
0&R 02217 3
See Page No(s):18 Provides valve specific information to response part B.2.d.
Update:
Revises response part 8.2.d to provide valve-specific.
information, as follows:
(1) Target Rock and ASCO solenoid valves qualification test temperatures exceed the maximum postulated temperature envelope inside containment (i.e. 345 degrees F), and (ii) the Valcor solenoid valves maximum qualification test / analysis temperature also exceeds 345 degrees F.
FSAR Change Request Number: 89-308.7 Related SSER Section: SSER6 3.11 SER/SSER Impact: Yes SSER 6. Section 3.11.3 has old values for valves.
Q&R 022-17 3
Revises discussion of containment electrical penetrations to provide specific information on qualification temperatures.
Revision:
Revises response to part B.2.c. to note the increase in containment electrical penetrations and header plate assemblies maximum qualification test temperature from 340 to in excess of 345 degrees F.
FSAR Change Request Number: 89-308.6 Related SSER Section: SSER6 3.11 SER/SSER Impact: Yes SSE4 6 Section 3.11.3 discusses old temperatures.
I s.
.=
'h:EncfosuratoTXX-89327.
CPSES/FSAR
'~
i4 pressure setpoint of HI-3 (20 psig) was.
^
' reached for large breaks., For.small-breaksL
- 76, the' spray delay time'is 38-seconds.
f.
Identification of most severe environment 5
.Among the MSLB's analyzed, the 0.908 ft2 5:
split rupture at 70-percent.: power results in the maximum Containment temperature. The, Containment vapor temperature for~ thia break is shown in. Figure 6.2.1-15.
2.
Safety Related Component Thermal: Analysis-5 The peak containment vapor temperature for the 76 design basis MSLB was calculated to be 345 F.
D Component thermal analyses are required only if the l5' environmental.' qualification test conditions are.
less than those calculated from the Containment pressure-temperature transient response analysis.
a.
Transmitters 5
7Md (ddiffiddfidd fidd fdt ttidf6fffdtg Mdd 5
ddf fdf 5ddd fidd7ffddl All transmitters located inside containment and required to operate for a design basis MSLB, to mitigate the accident consequences, are qualified 7Hd (ddlifiddfidd till Bd by testing or by a combination of testing and thermal analysis in accordance with IEEE 323-1974 requirements.
7M& tKitid1 ddd1}ilti if fd(ditidl till d6f16),
istidntif ditd611t%dd 6dtHddit b.
Electrical cables 5
The cables are qualified by testing / analysis 5
to a maximum temperature of 3453460F. The 022-16
LEnc,Tesure to TXX-89327 Page 20 of 21.-
CPSES/FSAR l
qualification method is-in accordance with IEEE 383-1074 and IEEE 323-1974. THd/dfd/dl J 5 dd fMdfddl Adliffit li /d(di/ddl l
c.
Containment' electrical penetration-5 diidd611di The Containment electrical penetrations and their header plate assemblies are qualified by testing to i ddAfddd temperatures exceeding 345'F df 3ded. The qualification method' f
is in accordance with IEEE 317-1976 and IEEE 323-1974. TMitifdfil 66 tYdtdal indifili !!
l5 fdfdifddl d.
Valves / Valve Operators 5
The valves located inside containment consist 5
of two groups:
(1)
Target Rock and ASCO solenoid yalyes are qualified by testing to d idAfddd temperatures df above 345 3460F, and I
\\
on 1
022-M #8
A
Encrosuro to TXX-89327 Paga 21 of 21 CPSES/FSAR lill tilidt figiifidd El tittidt t6 i E
6 66i1666 166$4titsf4 6f 180 Fl ind a
(ii)
Valcor solenoid valves are qualified by testing / analysis to a maximum temperature of 3468F.
The Limitorque operators of all valves located inside containment are qualified by testing to a maximum temperature significantly above 3458F. The qualification method for valves / valve operators is in accordance with IEEE 323-1974.
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(difffidd t6 366 fl M6 dittildd tMif641 iddlftit it 666tidifdd d
dilditiff 16f tH6 tilidt f66111144 t6 28t f 16f tMi 16116didd tidi6dil TM4 t46tiid6dit id$6f 166$4fitsfi ditiddi tMi 4dilifititi6d 166$4fitsf4 6dif 16f 4 iM6fi $4f164 6f tiddl 1544 Fiddfi 612/1/1511 TMd tilti $6fti iti filititill tMitKl t6didfdditif tMdit tMdf661 fit $66ti it di$ditid 16 54 ilde ippfdilditidd fMit 6f fHi C6dtild6ddt itid1 lidift j
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$fdtistd/tidfifititi fitf6dti t6 iMi ddiidd Mdili Msts idtidd 5tMidi Mdit tfidifdf d6ffiliti6d; idd d
iM6dd in Fiddfd 6ttt!/I71 it Ed16d 288 fl 3.
Evaluation of Environmental Qualification 5
The test temperature profiles used for 022-U /$
i