TXX-6885, Forwards Advanced FSAR Change Correcting Errors Contained in 871002 Rev to Environ Qualification Program.Ltr Supersedes Encls to TXX-6745

Forwards Advanced FSAR Change Correcting Errors Contained in 871002 Rev to Environ Qualification Program.Ltr Supersedes Encls to TXX-6745

ML20236G284
Person / Time
Site:	Comanche Peak
Issue date:	10/27/1987
From:	Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-R00239, TAC-R239, TXX-6885, NUDOCS 8711020483
Download: ML20236G284 (29)

Text

{{#Wiki_filter:__ ^b uman MM Log # TXX-6885 1 d Fi1e # 10010 = = 903.11 Ref # 10CFR50.49 M1 ELECTRIC l October 27, 1987 wmam c. counwi ' Esecu,ive M Presiden, V. S. Nuclear Regulatory Commission Attn: Document Control Desk . Washington, D. C. 20555-

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) DOCKET-N05. 50-445 AND 50-446 . ENVIRONMENTAL QUALIFICATION PROGRAM REVISION DEFINITION OF MILD ENVIRONMENTS l AT COMANCHE PEAK STEAM ELECTRIC STATION Gentlemen: i On March 13, 1987 we submitted to you for your concurrence TXX-6320, '" Implementation of' a Mild Environment Equipment Category at Comanche Peak ' Steam Electric Station," which defined CPSES's categorization of equipment . located in mild environment areas. Since then CPSES has modified this document to further simplify the definition and still remain within the guidelines'of the regulatory requirements. On October 2, 1987, TV Electric submitted TXX-6745, a revision to the CPSES Environmental Qualification Program, to address mild environment areas. That submittal contained errors in the definition of a potentially harsh environment. These errors have been corrected in the attached advance FSAR change. This letter supercedes the attachments to TXX-6745. However, formal commitments made in TXX-6745 are still valid. Very truly yours, 1 d.b W. G. Counsil l N kiogg g g7 5 By: A D. R. Woodlan 1 Supervisor, Docket Licensing VIP /tgj l Attachments I c-Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) \\ 1 i l l l 400 North Olise Street LB 81 Dallas Texas 7520) T u-6885 Octhber 27, 1987 Page 1 of 3 EflVIR0flMEflTAL QUALIFICATI0fl PROGRAM REVISI0fl TO ADDRESS flILD EflVIR0flMEilTS This letter provides the definition of a mild environment area to be incorporated into the Equipment Qualification Program at Comanche Peak Steam Electric Station (CPSES) and provides background information supporting the establishment of a mild environment area. The definition of a mild environment area will be incorporated into the CPSES Final Safety Analysis Report (FSAR) in a future amendment. An advance copy of the textual portion of this change is attached to this letter for your review. During the evolution of environmental qualification requirements from the General Design Criteria (i.e., 10CFR50, Appendix A., General Design Criterion

4) to specific requirements (i.e., current Standard Review Plan and 10CFR50.49), a distinction between equipment located in nuclear plant areas subjected to potentially " harsh" post-accident conditions and equipment located in areas subject to " mild" post-accident conditions has been recognized.

Harsh environment areas are areas subject to a potentially significant change in environmental conditions following postulated design basis events. For example, an area experiencing high temperature steam, high pressure, high radiation or, possibly, flooding conditions, due to a l postulated design basis event, is a harsh environment area. Conversely, an area not subject to significant adverse changes in environmental conditions is considered a mild environment area. The technical basis for the distinction is the concept of common mode failures of equipment. The failures of equipment in mild environment areas following a design basis event are not, by definition, the result of significant additional environmental stresses; and, therefore, would be random failures. Thus, equipment in a mild environment area need not be qualified to the same rigorous criteria as equipment in a harsh environment area. This distinction between harsh and mild environment areas is embodied in current regulatory criteria, i.e., 10CFR50.49 and the flRC Staff's Standard Review Plan. At CPSES, a self-initiated environmental qualification program validation and update are in progress to ensure continued program acceptability in light of the evolution in flRC interpretation and implementation of 10CFR50.49. The update involves a reevaluation of several environmental qualification program activities, e.g., qualification documentation, qualification maintenance requirements and qualification master equipment list verification. Without a distinction between mild and harsh environment aceas, the criteria used for these activities must be applied, across the board, to all electrical equipment important to safety. Expanding the CPSES Environmental Qualification Program to define and designate mild environment areas brings the CPSES Equipment Qualification Program into agreement with current regulatory requirements and significantly simplifies the qualification program updating effort. For CPSES, mild environment areas are defined as areas, outside the containment, that are not potentially harsh following a design basis accident. A potentially harsh environment is defined as an environment where safety-related equipment would experience, due to the direct effects of a design

Attachment 11;

-TXX-6885 October 27, 1987. Page:2.of ~ 3 1 ". basis accident 1(Loss of Coolant Accident, Main Steam Line Break, High. Energy ' Line Break or Moderate Energy Line Crack), any of the following parameters: ?a. An ambient ~ pressure increase greater than two pounds per square

inch (2 psi).above atmospheric, or b.-

An' ambient temperature increase greater than fise degrees-centigrade (50C or 90F) above the postulated maximum temperature based on. normal and anticipated operational occurrences, or .A total integrated radiation exposure dose of 1X101 rads Gamma. c. NOTE: For postulated radiation environments between IX103 and IX104 rads Gamma, the. design / purchase specifications for eiect onic equipment located in a mild environment.will not allov use of semiconductors susceptible to radiation damage less tLan IX104 rads Gamma. If radiation is the only harsh environment criterion exceeded for 7 an area and an evaluation concludes that the component materials- ~ for a piece of equipment have a radiation threshold leveT greater -{ than the postulated radiation environment, then, for purposes of i environmental qualification, the equipment will be considered to be located in a mild environment. The radiation threshold level ~is the lowest radiation exposure at which property changes in j component material is documented. Such documentation can b? from materials handbooks, textbooks, government reports, laboratory data, and industry sources. d. A. relative humidity value of 100%. The designation of mild environment areas permits the review of environment.al qualification to focus on the design / purchase specifications, test results, operational experience, and/or design data to assure that the equipment is capable of functioning in its mild environment area. Of course, the equipment originally purchased as Class lE equipment at CPSES was purchased to IEEE-323-1974 qualification requirements.* Therefore, test documentation prepared in'accordance with this standard would also provide acceptable documentation of qualification for mild environment areas. The replacement of equipment in mild environment areas will be based on a design life rather than a qualified life. Design life may be based on the manufacturer's rating, vendor's design or application analysis, testing or analysis, or an engineering analysis for the. specific environment. The CPSES FSAR will be' updated in a future amendment to incorporate the changes resulting from the definition of mild environment areas. Attachment - 2 is a summary of the textual changes. is the textual FSAR i pages as they will appear amended. All changes are identified by an amtndment har and the word "Rev."

~ Attachment 1 TXX-6885~ 0c,tober 27, 1987 Page 3 of 3 IEEE-323-1974 is institute of Electrical and Electronics Engineers Standard 323, dated 1974, "IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations". J IL-

Attachment'2 TXX-6885 October'27,'1987. I Page 1 of 2 4 Advance CPSES FSAR Amendment -Detailed Description FSAR Page (as amended) Description J I A(ti)-48 Update: Reflects current status of. WCAP8587, Revision 6-A, and references 10CFR50.49 statements of consideration for exception to Regulatory Guide 1.89 for Class IE equipment located in a mild environment' area. lA(fi)-56 Revision: Details how Class lE equipment located in a mild environment area will meet Regulatory Guide 1.100. lA(B)-47 Update: References 10CFR50.49 statements of consideration for exception to Regulatory Guide 1.89' for Class IE equipment located in a mild environment area. 3.'10ft-3 Revision: Details how Class lE equipment located in a mild environment' area will be seismically qualified. j Correction: "71" should have been 1971. 3.108-3 Revision: Details how Class lE equipment located in a mild environment area will.be seismically qualified. 3.llN-1 Revision: Defines a mild environment area at CPSES. 3.llN-2 Revision: Describes qualification program { as applied to Class lE equipment located J in a mild environment area. 3.118-2 Revision: Defines a mild environment area j i at CPSES. l 3.llD-2a Revision: Specifies environmental qualification testing as applying to equipment and components that could experience a potentially harsh j environment. I

TXX-6889 October 27, 1987 Page 2 of 2 FSAR Page (as' amended) Description 3.110-3 Revision:. Inserts "potentially harsh environment" as appropriate for program consistency with the definition of mild environment areas. -3.118-5 Revision: Inserts "in a potentially harsh : environment" for program consistency with the definition of mild environment areas. t -3.11B-6 Revision: Describes qualification program as applied to Class IE equipment located in a mild environment area. 3.118-7 Revision: Inserts "in a potentially harsh environment" for program consistency with the definition of mild environment areas. 3.118-10 Revision: Inserts "in a potentially harsh environment (i.e., inside containment)" for program consistency with the definition of mild' areas category. i Appendix 3A 1-1 Revision: Defines a mild environment area at CPSES, Editorial: Deletes paragraph currently duplicated on page 1-2. Appendix 3A 2-3 Revision: Defines qualification program as applied to Class lE Equipment located in a mild environment area. Appendix 3A 3-1 Revision: Delineates criteria of NUREG-0588 as not applicable to Class 1E equipment located in a mild environment area.

"N

Attachments 3 1TXX-6885,-

36 - Octobenu27, 1987 L .Page"1 of 23l ~) .u n b CPSES/FSAR-Discussion . The Westinghouse approach to satisfying the guidelines ~ of Regulatory Guide 1.89.(dated November,1974);andflEEE-Standard-323-1974;is documented in WCAP 8587, Revision 6-A, which has been reviewed and approved by the NRC. LHowever, as supported by the statements of consideration for 10CFR50.49 (Federal _ Rev. Register,- 48FR2731, January 21,11983), the recommendations of this regulatory guide need not be ~ applied forJ Class 1E~ equipment located in a mild environment : area. L'? Also: refer to. Appendix-1A(B); ~ h Regulatory Guide 1.90-i Cinservice, Inspection of Prestressed Concrete Containment Structures'with-Grouted Tendons ' Discussion l 'i LThis regulatory.guidelis not applicable to the CPSES. Regulatory Guide 1.91 Evalu~ation of Explosions Postulated to Occur on Transportation Routes Near . Nuclear Power Pla'nt Sites 1 k 1 ? 1A(H)-48 .l 1 1

TXX-6886 October 27, 1987 Page 2 of 23 CPSES/FSAR employed (i.e., test and/or analysis) is indicated, for the safety-related equipment in the Westinghouse scope of supply, in Reference 17. Where multifrequency biaxial inputs are employed for testing, the methodology described in Reference 18 will be employed. When flexible equipment siae and weight precludes biaxial testing (e.g., enclosures), single axis testing with justification will be utilized to meet IEEE Standard 344-1975. For rigid equipment (i.e., no resonant frequency below 33 hertz), qualification will be by analysis in accordance with IEEE Standard 344-1975. Rev. All Class IE equipment located in a mild environment area (as designated in FSAR Appendix 3A Tables 5-1 and 5-2) will be seismically qualified as-described above and in FSAR Sections 3.10H and 3.108, except that the additional requirements imposed by IEEE Standard 323-1974 do not apply. The design / purchase specifications will specify that.the effects of aging on seismic qualification be assessed and if there are aging effects, rec,uire pre-aging or analysis of aging effects as part of the seismic qualification. Refer to FSAR Section 3.10N. for further discussion of Regulatory Guide. Also refer to Appendix 1A(B). Regulatory Guide 1.101 Emergency Planning for Nuclear Power Plants Discussion Refer to Appendix 1A(B). Regulatory Guide 1.102 Flood Protection for Nuclear Power Plants Discussion Refer to Appendix 1A(0). IA(N)-56

. Attachment 3 l TXX-6885' j October 27, 1987 l l-Page 3 of 23 i CPSES/FSAR j I Discussion 1 The quality assurance program for design' and construction at CPSES j incorporates the intended objectives of ANSI N45.2.9 (Draf t 11, Revision 0, l 1/73). During the operations phase, the quality assurance methods and i administrative controls utilized for controlling and storing QA records, as described in Section 17.2, will comply with the applicable guidance provided 4 in ANSI N45.2.9-1974, as endorsed by Revision 2 (10/76) of this regulatory guide; except for paragraph 3 of section 5.6. For this exception, CPSES will L comply with paragraph 3 of section 5.6.1 of ANSI N45.2.9-1979, which requires a minimum two hour rating for the structure, doors, frames and hardware of the storage facility. Application of the requirements of Revision 2 (10/76) of this regulatory guide will be in accordance with the guidance provided in ANSI N18.7-1976. Regulatory Guide 1.89 Qualification of Class lE Equipment for Nuclear Power Plants. Discussion The CPSES Class 1E equipment design complies with the qualification program guidelines as delineated in this regulatory guide dated November 1974. However, as supported by the statements of consideration for 10CFR50.49 (FederalRegister,48FR2731, January 21,1983), the recommendations of this

Rev, regulatory guide need not be applied for Class 1E equipment located in a mild environment area.

Also refer to Appendix 1A(N). Regulatory Guide 1.90 Inservice Inspection of Prestressed Concrete Containment Structures with Grouted Tendons lA(B)-47

TX.X-6885 October 27, 1987 Page 4 of 23 CPSES/FSAR 3.10N.2 METHODS AtlD PROCEDURES FOR QUALIFYING ELECTRICAL EQUIPMENT AND INSTRUMENTATION In accordance with IEEE 344-1975, seismic qualification of safety related electrical equipment is demonstrated by either type testing, analysis or a combination of these methods. The choice of qualification method. employed by Westinghouse for a particular item of equipment is based upon many factors including; practicability, complexity of equipment, economics, availability of previous seismic qualification to earlier standards, etc. The qualification method employed for a particular item of equipment is identified in the individual Equipment Qualification Data Packages (EQDP's) of Reference 2. All NSSS safety related electrical equipment located in a mild environment area (as designated in FSAR Appendix 3A, Table 5-2) will be seismically qualified as described in FSAR Section 3.10N, except that the additional Rev., requirements imposed by IEEE Standard 323-1974 do not apply. The l design / purchase specifications will specify that the effects of aging on seismic qualification be assessed and if there are aging effects, require pre-aging or analysis of aging effects as part of the seismic qualification. l 3.10N.2.1 Seismic Qualification by Type Test From 1969 to mid-1974 Westinghouse seismic test procedures employed single Rev* I axis sine beat inputs in accordance with IEEE 344-1971 to seismically qualify j equipment. The input form selected by Westinghouse was chosen following an i investigation of building responses to seismic events as reported in Reference 3. In addition, Westinghouse has conducted seismic retesting of certain items of equipment as part of the Supplemental Qualification Program (Reference 4). This retesting was performed at the request of the NRC staff on agreed selected items of equipment employing multi-frequency, multi-axis test inputs-(Reference 5) to demonstrate the conservatism of the original sine-beat test method with respect to the modified methods of testing for complex equipment recommended by IEEE 344-1975. l The original single axis sine beat testing and the additional retesting completed under the Supplemental Test Program has been the subject of generic j review by the Staff. For equipment which has been previously qualified by the l single axis sine beat method and included in the NRC seismic audit and, where required by the Staff, the Supplemental I l 3.10N-3 i c _ _ __ - _ _ _.

,) reattachment ^3L TXX-6885: ' October (27,-19871 .Page;5:of 23L CPSES/FSAR-:. functional operability during and after an' earthquake of magnitude up to and . including the SSE. Seismic design of the Reactor Protection System and ESF' circuits.are discussed.in Section 3.10N. a All' electrical equipment and instrumentation mounted on or attached to the - -l Containment polar l crane, the Fuel: Building crane, the Containment rotating-1 ! access. platform, and the Service Water Intake. Structure crane are qual.ified as =j ' seismic' Category-I equipment with.the waiving of the requirement of functional i operab.ility during and following an SSE. llorizontal.. and. vertical ~ ground accelerations during an SSE are used to

formulate. floor; response. spectra at each equipment location as described in H

.Section 3.78.2.5 Equipment.and system specifications' include the appropriate-response spectra used for the analysis or testing ~of the equipment..The seismic qualification prograin for electrical equipment is as described in Section 3.78.2.1.3. Analysis is usedlfor the qualification of. equipment'of-relatively simple ~ geometry which can be modeled accurately. ' Suppliers are_ required to furnish documentation of actual test results~or detailed computations, if an analytical approachLis used, to substantiate' the-

capability of the equipment to perform its intended function under the

'specified conditions. Seismic Category I instrumentation.and electrical equipment are seismically .I qualified in -accordance with the procedures and documentation requirements specified'in IEEE.344-1975, Recommended Practices;for Seismic Qualification of-Class lE Equipment for Nuclear Power. Generating' Stations. For equipment in mild environment areas as identified.in Appendix 3A, Table 5-1, the: additional requirements-imposed by IEEE-Standard 323-1974 do not apply. For equipment in Rev* mild. environment areas, the design / purchase specifications will' require that the effects of aging on seismic qualification be assessed and, if there are aging effects, will require pre-aging or analysis of-aging effects as part of the seismic' qualification requirements. 3.108-3

TXX-6885 October 27, 1987 Page 6 of 23 CPSES/ESAR f 3.11N ENVIRONMENTAL DESIGN OF MECHANICAL AND ELECTRICAL EQUIPMENT The mechanical and electrical portions of the Engineered Safety Features and the Reactor Protection Systems are designed to ensure acceptable performance in all environments anticipated under normal, test, and design basis accident conditions. This section presents information on the design basis and qualification verifications for mechanical and electrical equipment in the Engineered Safety Features and the Reactor Protection System that are within the scope of the Westinghouse Nuclear Steam Supply System (NSSS). Section 3.7N presents the seismic design requirements and Section 3.10N presents the seismic qualification of electrical equipment. 3.- 11 N.1 EQUIPMENT IDENTIFICATION AND ENVIRONMENTAL, CONDITIONS A list of safety-related equipment located inside and outside Containment, required to function during and subsequent to an accident, is given in Appendix 3A, fable 5-2. Plant normal environments are listed in Table 3.118-2. Plant abnormal and accident environments for this equipment are provided in Appendix 3A, Table 5-2. Environmental qualification conditions of this equipment in the Westinghouse scope of supply will be based upon the approach delineated in References [1] and [3]. The safety-relafed mechanical equipment at CPSES has been designed to withstand environment effects as required by GDC-4 and Appendix B of 10 CFR Part 50. These requirements are satisfied through the design, specification, procurement, and quality assurance procedures used at CPSES as supplemented by the pump and value operability programs and the CPSES maintenance and surveillance programs. Safety-related equipment which is located in a mild environment area is designated in Appendix 3A, Table 5-2. For CPSES, mild environment areas are defined as areas, outside the containment, that are not potentially harsh following a design basis accident. A potentially harsh environment is defined as an environment where safety-related equipment would experience, due to the direct effects of a design basis accident (Loss of Coolant Accident, Main Steam Line Break, High Energy Line Break or Moderate Energy Line Crack), any of the following parameters: Rev. l a. An ambient pressure increase greater than two pounds per square inch (2 psi) above atmospheric, or b. An ambient temperature increase greater than five degrees centigrade (50C or 90F) above the postulated maximum temperature based on normal and anticipated operational occurrences, or 3.11N-1 l (

l Attachment 3 TXX-68853 10ctober 27,.1987 p Page,7 of!23 CPSES/FSAR ec. A: total integrated radiation exposure dose of-1X104' rads Gamma D NOTE: For postulated. radiation environments between 1X103 and 1x10 - 4 rads Gamma, the design / purchase specifications for electronic equipment located in a mild environment will.not allow use of semiconductors susceptible to radiation. damage less than IX10 - 4 rads Gamma. If radiation.is Lthe only harsh environment criterion exceeded. for an area ~and an evaluation concludes that-the component materials. Rev. for a piece of equipment have a radiation threshold level greater than the postulated radiation environment, then, for purposes'of environmental qualification, the equipment will be considered to be located inia mild environment. The radiation threshold level. is'the' lowest radiation exposure at-which property changes in component material is documented. Such documentation can be from materials handbooks, textbooks, government reports, laboratory - data -and. industry' sources. d. A relative humidity value of 100%. 1 i 1 3.llH-la-

l Attachment 3-TXX-6885 -October 27,-1987 Page 8 of 23 CPSES/FSAR -3.11N.2- -QUALIFICATION TESTS AND ANALYSIS For Westinghouse NSSS Class 1E equipment located in a potentially harsh environment, Westinghouse will meet the Institute of Electrical and Electronic Engineers (IEEE) Standard 323-1974, "lEEE Standard for Qualifying Class lE Equipment for Nuclear Power Generating Stations," includin 323a-1975, the Nuclear Power Engineering Committee (NPEC) g IEEE Standard Position Statement of July 24, 1975, by an appropriate combination of any or all of the following: type testing, operating experience, qualification by analysis, and on-going qualification. Topical report, WCAP-8587, " Environmental Qualification of Westinghouse Class 1E Equipment" (October 1975) has been revised and resubmitted to the staff as WCAP-8587, Revision 1, " Methodology For Qualifying Westinghouse PWR-SD Supplied NSSS Safety Related Electrical Equipment" (September, 1977). This revision to WCAP-8587 provided additional information requested by the staff concerning the methodology employed by Westinghouse to qualify safety related electrical. equipment. In response to NRC staff requests for further information on the details of the qualification program, Westinghouse submitted Supplement 1 to WCAP-8587, " Equipment Qualification Data Packages". This supplement describes the performance specifications and requirements and the proposed test plan for each piece of safety related electrical equipment. This material is applicable to, and should be reviewed on the Comanche Peak docket. Table 3.11N-3 identifies the Westinghouse supplied safety-related equipment and the corresponding Equipment Qualification Data Package contained in Supplement 1. For NSSS Class 1E equipment located in a mild environment area, CPSES will demonstrate qualification through design / purchase specifications, test results, operational experience, and/or design data. This information will contain a description of the functional requirements for the equipment's specific mild environmental area. Documentation which meets the requirements for a potentially harsh environment will be considered acceptable in lieu of the above requirements. However, the replacement of equipment located in a mild environment area will be based on a design life rather than a qualified Rev* life. The design life may be based on the manufacturer's rating, vendor's design or application analysis, testing or analysis, or an engineering analysis for the specific environment, as long as said determination is based on. conditions which are equivalent to or more conservative than the equipment's specific mild environment conditions. All Class 1E equipment located in a mild environment area will be seismically qualified to IEEE Standard 344-1975 and Regulatory Guide 1.100 using the methods, procedures, and documentation described in FSAR Sections 3.7 and 3.10N. l 3.11H-2 l i E_ _ _

I ~ Attachment 3' TXX-6885 i October 27, 1987 i Page 9-of 23 i 'CPSES/FSAR The overall Class IE Westinghouse equi generic environmental conditions, e.g pment qualification program includes , temperature, pressure,' relative humidity, chemistry, and radiation, which are established for the various pieces of Westinghouse supplied Class 1E equipment. - The conditions vary according to location of the equipment. The generic environmental conditions 4 for which the equipment is qualified are reported in the specific Equipment The-Qualification Data Package. The i s <k 1 i 1 l I 3.11fl-2a 1

l TXX-6385 October 27, 1987 Page 10 of 23 CPSES/FSAR I i The environmental qualification program at CPSES includes all Class 1E l equipment, including that located in mild and potentially harsh environment areas, as identified in. Appendix 3A, Table 5-1. For CPSES, mild environment l areas are defined as areas, outside the containment, that are not potentially i harsh following a design basis accident. A potentially harsh environment is defined as an environment where safety-related equipment would experience, due to the direct effects of a design basis accident (Loss of Coolant Accident, Main Stecn Line Break, liigh Energy Line Break or Moderate Energy Line Crack), l any of the following parameters: An ambient pressure increase greater than two pounds per square a. inch (2 psi) above atmospheric, or i I b. An ambient temperature increase greater than five degrees centigrade (50C or 90F) above the postulated maximum temperature based on normal and anticipated operational occurrences, or c. A total integrated radiation exposure dose of 1X104 rads Gamma. fl0TE: For postulated radiation environments between IX103 and.1X104 rads Gamma, the design / purchase specifications for electronic i equipment located in a mild environment will not allow use of semiconductors susceptible to radiation damage less than IX104 rads Gamma. Rev. If radiation is the only harsh environment criterion exceeded for an area and an evaluation concludes that the component materials for a piece of equipment have a radiation threshold level greater than the postulated radiation environment, then, for purposes of environmental qualification, the equipment wil1 be considered.to be located in a mild environment. The radiation threshold level is the lowest-radiation exposure at which property changes in component material is documented. Such documentation can be from materials handbooks, textbooks, government reports, laboratory data,. and industry sources. d. A relative humidity value of 100%. Upper limit plant normal (operating) conditions (pressure, temperature, and relative humidity) are given in Table 3.118-2. _ Plant accident environmental conditions (pressure, temperature, chemistry, relative humidity, and ' integrated normal / accident radiation dose) are given in Appendix 3A Table 5-1. 3 Environmental qualification documentation for Class lE equipment is retained in the plant records.

The ESF and other safety-related equipment which must remain operable during and af ter the DBA are further discussed in appropriate chapters of the FSAR as follows:

3.118-2 l a

w TXX-6885 October 27, 1987 Page 11 of 23 CPSES/FSAR 1. ESF and other Safety-Related Equipment Located Inside Containment a. Mechanical equipment (which contains Class IE electrical components) in Chapter 6. b. Class lE. equipment in Chapter 8 c. Instrumentation and controls in Chapter 7 2. ESF and other Safety-Related Equipment Located Outside Containment Mechanical equipment (which contains Class lE electrical a. components) is described in Chapters 6, 9, and 10. b. Instrumentation and controls are described in Chapter 7. Class IE equipment is described in Chapter 8. c. The safety-related mechanical equipment at CPSES has been designed to withstand environmental effects as required by GDC-4 and Appendix B of 10 CFR Part 50. These requirements are satisfied through the design, specification, procurement, and quality assurance procedures used at CPSES as supplemented by the pump and valve operability programs and the CPSES maintenance and surveillance programs. fable 3.118-5 presents' data on HELB's. This table addresses the Class lE equipment that could experience environmental extremes due to an HELB and the non-Class 1E equipment needed to mitigate the HELB. The equipment needed to mitigate an HELB and the equipment in the areas affected by the HELB which are needed to safely shutdown are so designated in Table 3.11B-5. The equipment selection is based on the HELB studies discussed in Section 3.68.1.2.3 and the ilELB mitigation schemes discussed in Section 7.6. 3.118.2 QUALIFICAT10f1 TESTS Af10 AtlALYSES Qualificat' ion tests and analyses are performed on all ESF equipment and

Rev, components that could experience a potentially harsh environment as necessary to ensure their availability during and af ter a DBA.

These tests consist of simulation of actual physical conditions on the equipment or a prototype on a generic basis, or analysis, or a combination of prototype tests and analysis as applicable. Qualification testing is performed under simulated conditions of temperature, pressure, relative humidity, chemistry, and radiation dose in excess of those expected for post-DBA conditions. The testing period is (~ suf ficient to ensure the capability to function during and af ter a DBA. i I t j 3.llB-2a w_-_-_____-__

L l l' TXX-6885 [ October 27, 1987 Page 12 of 23 CPSES/FSAR In order to provide assurance that all ESF and other Safety Related equipment Rev* that'could experience a potentially harsh environment has capability to meet environmental conditions as required, the appropriate quality assurance programs are established and implemented. Class 1E instrumentation and electrical equipment in a potentially harse environment are capable of~ operating in the worst expected environmental Rev. conditions as specified for each component and its location in Appendix 3A, - Table 5-1. This Class'1E electrical equipment is specified for manufacture in accordance with the criteria listed in Section 8.3. All such Class IE equipment will be qualified per IEEE 323 [11] and other applicable standards per Section 8.3 and below. I 4 IEEE-323-1974 requirements include the need to establish the qualified life of Class 1E equipment. This requirement has, in many cases, represented a' state-l of-the-art challenge in assessing the longevity of equipment under normal and i dCCident environments. Many of the equipment qualification tests reports have identified relatively shorter lives of certain components. In some cases, these estimated, seemingly short, qualified lives may be the result of testing or accelerated aging limitation, rather than due to intrinsic equipment limitations. TUGCO, as the first operating license applicant with an IEEE- ' 323-74 commitment has been confronted with an enormous developmental program in meeting these new requirements. Consistent with TUGCO's commitment to meet the requirements of IEEE-323-1974 subject to state-of-the-art limitations, TVGC0 will modify any of the currently. listed qualified lives as additional information and better testing and analytical techniques are developed. Therefore, the qualified lives currently listed should be regarded as decision points with regard to an ongoing aging evaluation, rather than a fixed component replacement interval. Changes from those qualified lives currently indicated will be documented by i revisions to the appropriate qualification documents and/or approving additional qualification documents. i l i 1 3.110-3 l ) l q l l h.__.id.m.,_____-..---.

TXX-6885 4 (October 27, 1987 Page 13 of 23 CPSES/FSAR - Qualification tests for all safety related electric valve operators outside as well as-inside containment are designed in accordance with References [8, 11, 13 and 15] to demonstrate their capability to function during and af ter accident environmental conditions. In addition, safety related electric valve operators installed inside the containment are also qualified in accordance with R.G. 1.73 [6]. I 2The Class:1E-instrumentation and control equipment in a potentially harsh } environment and designated Accident Monitoring equipment (see FSAR Section Rev. 7.5) have been qualified in accordance with IEEE 344-1975 and IEEE 323-1974 criteria. Because the Containment has no Class 1E motors which are required to operate on a continuous basis during or following a DBA, HRC Regulatory Guide 1.40 [3] is not applicable to CPSES. Safety related equipment located inside the Containment that must remain operable during a DBA are listed in Appendix 3A, Table 5-1. As indicated in the list referenced previously, the only motors in the Containment required to l operate in the event of a DBA are those motor-operated isolation valves which operate at the onset of a DBA. The' Class 1E motors located outside the Containment are type-tested in accordance with the intent of IEEE 334-1974 [12]. The initial preoperational test procedures incorporate the recommendations of NRC Regulatory Guide 1.41 [4] for verifying proper load group assignment. Provisions are integrated-into the design criteria for required test circuitry, undervoltage-sensing relays, and simulated accident test signals to permit testing as outl,ined in Regulatory Guide 1.41. m 3.118-5 l l l u-

'iAttacfiment 31

TXX-688'S

" October 27,-1987 .Page'14-of 23. CPSES/FSAR I JSubsequent to the" initial service'date, the station st'andard. maintenance and { f test procedures l require that any major modification or repair to the.onsite -power systems or. redundant load groups necessitates retesti.ng of these systems-to. verify independence among redundant. systems. The design ~ basis for the maintenance, testing, < and replacement. of plant-- batteriesLislin compliance with the recommendations set forth in IEEE'450-1 '1980, as discussed in Section 8.3.2. J Inspections of the batteries are described in-Section 8.3. It is not proposed to. test equipment of a passive nature, such as' primary.and! l secondary shielding. j . Qualification: tests for electric penetration assemblies are: based on-References-[10 and 11]. Qualification tests' forl electric cables are based on References -[11 and 16] i . For Class lE equipment. located in a mild environment area, CPSES will l demonstrate qualification through design / purchase specifications, test results, operational' experience,.and/or design data. This information will contain a, description of the functional requirements for the equipment's

specific mild environmental area.. Documentation which meets the requirements-for. a potentially' harsh environment will be considered acceptable in. lieu of.

[ the!above requirements. However, the replacement of equipment located in a mild environment area will be based on a design life rather than a qualifie~d Rev*I life. The design. life may be based on the manufacturer's. rating, vendor's I . design'or application analysis, testing or analysis, or an engineering. analysis for the specific environment, as long as said detennination is based ) on conditions which are equivalent to or more conservative than the equipment'slspe.cific mild environment conditions. All Class 1E equipment located in a mild environment will be seismically qualified to IEEE Standard 344-1975 and Regulatory Guide 1.100 using the methods, procedures, and documentation described in FSAR Sections 3.7 and 3.108. t How the requirements of GDC 1, 24, 23 and 50 are met is addressed in Section i ) 3.1.. Specific information concerning how GDC-1 and 4 are met is reported in ' Appendix'A of Reference.[18]. 1 Specific information concerning how GOC 23 is met can be found in Sections 7.2 and 7.3. L [ 3.110-6 i \\ l 2.

. Attachment 3 TXX-6885 October 27, 1987 Page 15 of 23 CPSES/FSAR The quality assurance program to be applied to the design, fabrication and testing of all B0P safety related equipment conform to the requirements of 10CFR part 50 Appendix 8. The QA program is described in Chapter 17. l Specific information concerning how Appendix B of 10 CFR Part 50 is met is discussed in Chapter 17. Level of compliance with NRC Regulatory Guides 1.30, 1.40, 1.63, 1.73, 1.89 and 1.131 is addressed in Appendix 1A(B). 3.llB-6a

LAttachment 3 TXX-6885: (October 27, 1987. Page 16.of.23 'CPSES/FSAR-j i l3.118.3 QUALIFICATION TEST RESULTS' .All safety-related equipment.and components in a potentially. harsh environme;c. will.be. demonstrated to perform their designed safety. function under.all Rev. normal, abnormal and. accident conditions, by appropriate testing and analys~es. .The detailed qualification information and.-test results when completed will be available for an NRC audit.- A summary of the test results is provided in Appendix.3A, Table 5-1. 3.11B;4

LOSS OF VENTILATION 3.118.4.1

Environmental Design Basis The' plant -design features insure that room ambient temperattires do not. exceed.

the maximum operational temperature limit for instrumentation and electrical ' equipment. .1. Control Room Ventilation System The Control Room air-conditioning system'is designed to maintain its l. ambient temperature at or below 800F and 50 percent relative-humidity. l' The system 'is of seismic Category I design and includes the.following design features: . Sufficient redundancy in equipment and power supplies cis provided a. to enable the system to-sustain a single active component failure without' loss of safety function. .b.. Redundant. fans are connected'to separate Class-IE buses as described in Section 8.3. c. Instrumentation and controls which incorporate audible-and visual alarms enable _the operator to continuously monitor system performance and alert him in the event of system malfunction, l 3.118-7 [ V

-s m Attachments 3 b, 'TKX-6885~ y L ," October 27. 1987-F, Page.17 of.23 g .f 'CPSES/FSAR -3.'118.5" . ESTIMATED CHEMICAL AfID RADIAT10tl EllVIR0tlMEtiT 3.118.5.1. Chemical Environment yihe majority of' pressure boundary components are. constructed principally of- ~ stainless steel.; Containment structures are principally constructed of. ' concrete and carbon steel.(galvanized or coating).. These materials are . compatible with,' and.do not suf fer significant. degradation in the containment spray environment. Othe'r~ pressure boundary' component (i.e. gaskets) ~ materials r 'are-also. selected for their compatibility with'the spray environment. L0etails concerning-the chemicals used in and the chemistry of the containment . spray system is presented.in Sections:6.2.2 and 6.5.2. Accident chemistry qualification'of the safety-related electrical and instrumentation components ReV-in a potential! ~ harsh environment (i.e., inside containment) is shown in Appendix.3A, Ta le 5-1.- The atmosphere-inside the containment building af ter a LOCA consists of steam-air-water mixture with 2300 ppm boric acid buffered with sodium hydroxide (tla0ll) to increase'the final spray solution ph to between 8.6 to 10. 3.118.5.2 Radiation Environment The radiation environment 'for normal operation and for the DBA for each ' safety-related component has been determined.- The accident exposure criteria are based on'the TID-14844 [18] release model and, accordingly, are consistent with flRC Regulatory Guide l.4 [1]. Additional conservative assumptions used in determining these upper-bound postaccident dose levels inside.the . Containment are as follows: 3.110-10

. Attachment 3 TXX-6885 '0ctober 27, 1987 Page 18 of 23 I CPSES/EQR p 1,0 IflTR000CT10N This Equipment Qualification Report (EQR) supports the operating license application for Comanche Peak Steam Electric Station (CPSES). This report. provides design information in sufficient detail to allow a definitive evaluation of the equipment environmental qualification program for CPSES. j The CPSES environmental quali/ication program is described in Section 2.0 and a detailed comparison to NUREG-0588 is provided in Section 3.0. Specific 1 equipment review status is documented in Section 4.0 and a sunnnary of the postulated equipment accident / abnormal environment parameters used as the basis for qualification is in Section 5.0. Differentiation between equipment in a "potentially harsh" or in a " mild" environment area is also made in Section 5.0. The basic scope of the program includes all Class lE equipment at CPSES. Detailed system and equipment descriptions are included in the appropriate ( sections of the FSAR; in particular, those equipments required for Hot Stand - by and Cold Shutdown are described in FSAR Section 7.4. Section 7.1 identifies all safety-related systems. J A mild environment is an environment that would at no time be significantly more severe than the environment that would occur during normal plant-

Rey, operation, including anticipated operational occurrences.

For CPSES, mild environment areas are defined as areas, outside the containment, that are not potentially harsh following a design basis accident. A potentially harsh environment is defined as an environment where safety-related equipment would experience, due to the direct effects of a design basis accident (Loss of Coolant Accident, Main Steam Line Break, High Energy Line Break or Moderate Energy Line Crack), any of the following parameters: An ambient pressure increase greater than two pounds per square a. t inch (2 psi) above atmospheric, or b. An ambient temperature increase greater than five degrees centigrade (50C or 90F) above the postulated maximum temperature based on normal and anticipated operational occurrences, or i c. A total integrated radiation exposure dose of 1X104 rads Gamma. 1 NOTE: For' postulated radiation environments between IX103 and IX104 rads Gamma, the design / purchase specifications for electronic / equipment located in a mild environment will not allow use of semiconductors susceptible to radiation damage less than IX104 { rads Gamma. I l l-1 i 1 1 t

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' Attachment 3 ?^ TXX-6885- ..%I[. October 27,,1987 t F Page 19_of~23 l ( if e e '#yg CPSES/EQR If radiation is the orgy harsh environment criterion exceeded for an area and,-an evaluation concludes that the component materials for a piec6fof equipme6i have a radiation threshold level greater than the postulated: radiation environment, then, for purposes of I envircemental qualification, the equipment will be considered to be located in a mi% environment. The radiation threshold level Rev. l l is the, lowest radiation exposure at'which property changes in (c. ' component materid) 1s documented. ' Such documentation can be from materials hqndbooks, textbooks, government reports, laboratory data, and industry sources. - p d. Arelativel}bmidityvalueof100%. o, i Jb Safety-rel'ated equipmentBocettd in a mild environment area is not required to meet the requirements of UUREG-0588 or the guidelines of Regulatory Guide l 1.89. t i f f ) y' y { l-la 7 6 k, I i i JL-.__..._.__ 1

L f' ' Attachment 3 TXX-688'5 October 27, 1987 Page 20 of 23 CPSES/ EOR For NSSS Class 1E equipment located in a mild environment area, CPSES will demonstrate qualification through their design / purchase specifications, test results, operational. experience, and/or design data. This information will ' contain a description of the functional requirements for the equipment's specific mild environmental area. Documentation which meets the requirements for potentially harsh environment will be considered acceptable in lieu of the above requirements. However, the replacement of equipment located in a mild environment area will be based on a design life rather than a qualified life. The design life may be based on the manufacturer's rating, vendor's design or application analysis, testing or analysis, or an engineering analysis for the specific environment, as long as said determination is based on conditions which are equivalent to or more conservative than the equipment's specific mild environment conditions. All Class IE equipment located in a mild environment area will be seismically qualified to IEEE Standard 344-1975 and Regulatory Guide 1 100 using the Rev. - methods, procedures, and documentation described in FSAR Sections 3.7, 3.10N,. and 3.108. Note: The additional requirements imposed by IEEE Standard 323-1974 and Regulatory Guide 1.89 do not apply. The design / purchase specifications will specify that the effects of aging on seismic qualification be assessed and if there are aging effects, require pre-aging or analysis of aging effects as part of the seisn,ic qualification. All documentation for Class 1E equipment in a mild environment area will be maintained in the Environmental Qualification Files. These auditable files are updated and kept current as equipment is qualification tested, replaced or modified. To ensure that a well supported maintenance / surveillance program, in conjunction with a good preventative maintenance program, is established for all Class IE equipment in mild environment areas, this equipment will be included in the review and maintenance programs for Class IE equipment in a potentially harsh environment, as described in Section 2, modified as described in these individual sections to reflect the differing documentation which is required for environmental qualification (i.e., the design / purchase specifications, test results, operational experience, and/or design data and seismic qualification will be reviewed versus the vendor environmental qualification reports). 1-lb I ._.h_.___

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,; g l W t CPSES/EQR: tb Q 1..1 s b - The overall revier,t of. the programs is documented in Section 3.0 where each program (B0P and NSSS) is compared'to NUREG-0588. 'Each item by item corgarhun' describes how the -respective prograna meets each requirement icf L NUREG-05Sd. ':C f 4 .- [ %. AL status ch,the ppecific reviews of e%aCn type of ryk,ipment' is% vided in l 3 . Sr(tion 4.0. The. criteria used Mr hese revi k3-is provided h Section 6.0. TW reviews are conducted in accord se with appr ed procedurnp#and are subject.ty audit and Mview'by Quali y Assurance.g't .A ,h/ p I m 'firpl step in the7 qualification of each type ot Class K electrical eqdpm d in the' acceptance of that equipment with its iW6vidual-f quarifi k tion-program for CPSES. This acceptance.is doctrdnted on the f icMification forms as statused in'Section 4.0. ' The criteria for this

agspfance(isprovidedinSection7.0.

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and demonstrates the level of. inalvement by the applicant.4lification_ program j (

i All envirc9 mental qualification dats are contained in specific environmental qualificat,in packages which are maintained i,n ithe Environment,al Qualification C.

Files. Thede,auditable. files are upt.ted and kept' current as equipment is % '7t\\ ' n ' tested : replaced or rooc.fieds l %[cqualificatiji D 3G Q \\ Rev. t- ,^, ~g 4 For' Class y/ electrical equipment located 1@j results, operat y uild envircrpient' area, a 7:eview-s .j of the desi;gn/ purchase specifications, te;i arid /or ded;gn data, and appropriate sei<smiqqualification documentation will V* :. bemadeforeachequipsenttypeusi%apdrovedprocedureswhi are subject'to 1 audit'and. review by Quality Assuranc3. All documentation fcd dlass IE equipment in a mild environment area will be maintained in the Environmental- .4 Qualification Files, j 4 3n j?g Section5provides~asummaryoftheenvironmetal$alificationdatain 6j n J 'p easily-auditable format. t 'g q' 1 V 2.4CPSESQUALIFICATIONMAINTENNICEPR0dRAd l f-1 4 7 ~ b 'y' The Qualification Maintenance Pr) gram at CPSES is designed to be inte/Jjrated r ~ into the existing maintenance program while assuring that all qualified life-contingencies and qualification requirements W e Mul illed. The Qualification Maintenance' Program consists if m..iintddnce Mtivitic{s which in maty cases, 3' r: j occur norma *1p at' a powerylant., but/ that ar'e formalized in,the case of Class

/ p 1E electrical equ@ rant. Jily program.is. applied equi,lly/,tc Clasi IE l

t equipment in ~a potedieUy harsh and in a ' mild,envVronsent, except that the 'j. followird tqrms should be substituted form $ enc 6nnient application: 1) Rev. "de' sign ' W" for " qualified. life" and. 2) '"A@gn/purchass speci fications, 3 y ' test, rem M L. ope:Ie6iothli experie'ncesand/or dsign data, and appropriate seisdis qu Rification documentation"'for " qualification requirements," juhlification reports," " equipment's 9:alifidhtion, v p "equ) ;nent " quai ficWion,"'or " qualification report". p q 2-3 g / 1 1 4, '4 L n

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TXX-6885L

.0ctober 27,T1987?

Page 21 of.~23)

.'CPSES/EQR 3 2- ~ .The'. basic scope o'f the CPSES(environmental qualificat' ion program which will-qualify. equipment to the standards of IEEE 344-1975 and IEEE 323-1974, includes allisafety related Class 1E equipment located in a potentially harsh -environment,1 designated Accident Monitoring-equipment (see FSAR Section.7.5), and any other electrical equipment which'CPSES has'committedito qualify in Rev.

accordance with.these criteria., All safety-related systems are identified.in:

FSAR'Section'7.l., Detailed' system'an'dequihmentdescriptions-are, included'in the appropriate sections of the FSAR; in particular, 'those equipments required .for Hot' Standby and Cold Shutdown are described in FSA_R Section 7.4..A list of equipment'which is classified as safety class-1E is provided in FSAR Table: 17A-1. -Ai review has been conducted of the CPSES' Emergency-Operating procedures. The review. identified all display instrumentation. referenced by the emergency d

operating procedures andilisted the safety classification for these

. instruments.. This review'~ verified that the= monitoring instrumentation as. s ( described in FSAR Section 7.5'istadequate-for.the execution of.the emergency 4 ' operating ' procedures. Modifications to the CPSES. design'due to-the incorporation of-TMI lessons. learned have been included into this Environmental Qualificatioit Report to the 1 extent.that these modifications;have'been defined.- The EQR.shall be' updated 'as'the: engineering progresses until all.such. modifications are fully defined.. 'I. . ~ \\ 1 z j 4 1-Ic K m W

s 4, ':lWi . Attachment 3 l sTXX-6885 I; October 27, 1987 Page 23 of.23. CPSES/EQR 3.0 CPSES COMPARIS0fl TO flVREG-0588 The'CPSES environmental qualification program has been reviewed using the. criteria provided in NUREG-0588. The results of this review are provided in Tables 3-1 and 3-2.. These tables describe the BOP and NSSS qualification Rev. programs, respectively, relative to each criteria in NUREG-0588. As defined in Section 1.0, the scope of this program does not include equipment which is located in a mild environment area. I l 3-1 1 l 1 l l 1 .-}}