ML20052F332

Responds to 820309 Request for Addl Info Re Equipment Qualification.Encl Responses to Questions CS 270.1,CS 270.2, CS 270.4 - CS 270.9 Will Be Incorporated Into PSAR Amend 69 by 820521

ML20052F332
Person / Time
Site:	Clinch River
Issue date:	05/07/1982
From:	Longenecker J ENERGY, DEPT. OF
To:	Checks P Office of Nuclear Reactor Regulation
References
HQ:S:82:026, HQ:S:82:26, NUDOCS 8205120354
Download: ML20052F332 (18)

Text

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Department of Energy Washington, D.C. 20585 May 7,1982 m

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Docket No. 50-537 HQ:S:82:026 9 'D Mr. Paul S. Check, Director 97

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G1 CRBRP Program Office 'O g //

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Cu y

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Washington, D.C. 20555

Dear Mr. Check:

RESPONSES TO REQUEST FOR ADDITIONAL INFORtMTION - EQUIPMENT QUALIFICATION

Reference:

Letter, P. S. Check to J. R. Longenecker, "CRBRP Request for Additional Information," dated March 9,1982 This letter formally responds to your request for additional information contained in the referenced letter.

Enclosed are responses to questions CS 270.1, CS 270.2, and CS 270.4 through CS 270.9 in the area of equipment qualification. These responses will also be incorporated into the PSAR in Amendment 69, scheduled for May 21.

Sinc ely A) h John R. Longenecker, Manager Licensing & Environmental Coordination Office of Nuclear Energy Enclosure cc: Service List pooIy Standard Distribution Licensing Distribution

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8205120354 020507 DR ADOCK 05000537 PDR

Page-1(82-0254)[8,22] - #28 Question _OCS 270.1 (3.11)

% e NRC staff position of environmental qualification of electrical equipent is discussed in NUREG-0588. Discuss your compliance with these requirements.

If you intend to use WARD-D-0165, "CRBRP Requirements for Environmental Qualification of Class lE Quipent", identify any differences between IEEE 323,1974 and the NUREG-0588 Category I requirements and discuss how the CRBR design complies with the NUREG-0588, Category I requirements.

Response .

W e CRBRP program for environmental qualification of safety-related electrical equipent, WARD-D-0165, is consistent with the objectives and requirements delineated in NUREG-0588, Rev.1 " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Quiprent", except as noted below.

Differences in CRBRP reactor technology and plant configurations exist and, as a result, some specific IMR requirements delineated in NUREG-0588 are not applied to CRBRP. These differences are: the use of liquid metal sodium for the reactor coolant; a low pressure coolant system with no mechanism for a highly pressurized containment; the absence of steam, containment spray, and the mechanism for water flooding within the containment; environmental separation of the upper containment from the lower containment; and placment of redundant heat transport loops in separate cells resulting in independent loop environmental conditions (environments in one loop do not propagate to the cells of another loop) .

Paragraph 2.4 of the NUREG-0588, Category 1 requirements, discuss "Other Qualification Methods". In this regard, CRBRP requirements permit type testing, analysis, prior operating experience and/or a combination of these techniques for equipnent qualification. An evaluation of the adequacy of the proposed method would be done before using analysis or operating experience in lieu of testing. Also an evaluation would be done to determine the necessary extent of any partial type tests required to be provided in support of these methods.

In addition to the design differences stated above, CRBRP does not apply two NRC staff positions stated in NUREG-0588. %e first exception deals with the radiation source term used for qualifying Class 1E equipnent located within the containment. NURIn-0588 specifies the worst radiation environment as an instantaneous release from the fuel to the atmosphere of 100 percent of the nobic gases, 50 percent of the iodines, and 1 percent of the remaining fission products. CRBRP uses the normally expected radiation environment over the equignent qualified life plus that associated with the most severe design basis accident during or following which the equipnent must renain functional.

ne worst case radiation IBA is the In-Containment Primary Sodium Storage Tank failure during maintenance. The second exception concerns the application of time margin to safety-related equipnent which performs its safety function QCS270.1-1 Amend. 68 May 1982

Rage-2(82-0254) [8,22] - #28 within a short time period into the event (i.e., less than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />).- In NURm-0588 a minimum qualification time margin of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is specified. CRBRP requires that equiptent be qualified for the environment in which it must perform its safety function for the time duration specified for the safety response plus time margin per IEEE 323-1974. Failure of any equipnent af ter its qualification time (whether longer or shorter than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) will not result in unsafe plant conditions.

i QCS270.1-2 Amend. 68 May 1982 I rsteso _ _ _

Page-3 (82-0254) [8,22] - #28 Question CS 270.2 (3.11.1)

Confirm that Section 3.2 contains all safety-related systens (including display instrumentation which is required by the plant emergency procedures) requiring environmental qualification.

Response

section 3.2 of the PSAR contains a generic list of all CRBRP safety-related electrical equipnent. This list does not differentiate between the various instrumentation and control devices, e.g. , Tenperature Sensors (RTD's or - -

thermocouples), Tenperature controllers, Tunperature Indicators (display),

etc. A comprehensive list of CRBRP Class IE equignent, including display instrumentation, is provided in Tables 3-1 and 3-2 of WARD-ir0165, "CRBRP Requirements for Environmental Qualification of Class lE RIuignent," (Ref.13, PSAR Section 1.6).

QCS270.2-1 i

hrend. 68

! 82-0254 __

Page-5 (82-0254) [8,22] - #28 Question OCS 270.4 (3.111 Discuss how you intend to account for the uncertainties caused by the production errors and errors associated with defining satisfactory performance when only a small number of units are tested. This margin should be in addition to the margin applied during the derivation of the specified plant parameters and margin applied to account for the instrument error during testing.

ResDonse CRBRP conservatively calculates the most severe specified service conditions that include accident environments that result from a review of all design basis events. The events that produce the most severe environmental transient are used. Often this would require multiple design basis accidents occurring to generate the most severe environmental conditions (temperature, pressure, radiation, humidity, etc.) . These conservatisms assure rargins between the service conditions specified and the actual conditions which could realistically be expected in a design basis event. Quantifiable margin is then applied to the conservatively calculated most severe service condition design parameters as per IEEE 323, Section 6.3.1.5.

In defining the type testing, the margin applied to the test profile envelops the specified design condition profile. In addition to applying margin to the environmental parameters, margin is added to the test duration. Further margin is applied in type testing by adding a margin transient (Section 4.2.2, step #7 of WARD-I)-0165 "CRBRP Requirements for Environmental Qualification of Class IE B]uipnent") .

'Ihrough application of these margins, CRBRP accounts for uncertainties associated with reasonable error in defining satisfactory perforrance when a smil number of units is tested, normal variations in the commercial production of equipnent, and accuracies of data resulting from type test measurements.

When conducting a type test for an item being qualified, an acceptance test is performed to assure that production problans do not exist. Also the equipnent specification requirements assure that the delivered plant equipnent design and manufacture is verified by inspection, testing (such as factory tests, burn-in tests, system tests, etc.), design control measures, and quality assurance methods.

QCS270.4-1 Amend. 68 May 1982 82-0254 _

Page-6(82-0254) [8,22] - #28 Question OCS 270.5 (3.lH Since equipment may be exposed to a sodium aerosol environment and this condition is unique to CRBRP, describe in detail how you plan to qualify the equipent for the sodium aerosol environment. Provide the results of the testing performed to date. How do you assure the operability of diesel generators in the sodium aerosol environment?

ResDonse CRBRP requires that Class lE equipnent which is rquired to perform its sa'fety' function during or after exposure to a sodium aerosol environment, must be qualified for the sodium aerosol environment. 'Ivo specific aerosol environments are identified. Sodium aerosol environments within cells where sodium aerosols originate or within cells that directly ingest significant quantities of sodium aerosols are specified " severe sodium aerosol environments". Extremely low sodium aerosol environments in air filled cells, other than those in which the aerosols originate, are classified as a "non-severe sodium aerosol environment". RIuipnent in the low sodium aerosol environment is located in general plant areas outside containment. This equipnent does not experience any significant changes in its service conditions due to a design basis event which has occurred in another plant location.

Class lE equipnent required to function within non-severe or severe sodium aerosol environments is required to be qualified by rsing either analysis, type testing, prior operating experience, or a combination of the previous qualification methods. The qualification procedure must comply with IEEE 323-1974 and IEEE 344-1975 as endorsed by FG 1.89 and RG 1.100 respectively, with application of pertinent NURIE 0588 guidance as discussed in Response CS 270.1.

For equignent required to function within severe sodium aerosol environments; the equignent is aged to its end of life condition, subjected to the seismic / vibration condition, and then exposed to the worst case Design Basis Event transients (temperature, pressure, radiation, humidity, sodium aerosols). The equipneat being type tested is rquired to be either identical to the plant hardware or all differences existing must be identified and justification provided that the differences do not affect the qualification results. Prior to subjecting equipnent to this type test, equipnent specification acceptance testing must be completed. The type tests shall be performed in the numerical order to meet the requirements of IEEE 323-1974, paragraph 6.3.2 as well as the requirements specified in WARD-D-0165, Section 4.2.2.

Where equipnent is required to function within non-severe sodium aerosol environments; the equipnent will be placed in its end of life state where required, subjected to off normal temperature, humidity and sodium aerosol environments, and then exposed to the seismic / vibration environment. 'Ibe CRBRP aging program for equipnent located in non-severe environments permits equipnent and catponents to be excluded from the stimulated aging requirment QCS270.5-1 Amend. 68 May 1982 asuman

Page-7(82-0254) [8,22] - #28 based on documented demonstration of no significant degradation of pertinent properties during its projected installed service life provided scheduled maintenance, surveillance and inspection is properly performed.

% e qualification test sequences depicted above are the most severe test sequences. Equip ent located in severe environments is exposed to the most severe Design Basis Event transients last, since exposing the test its to the most severe environment after exposure to the lesser environmental parameters results in the most severe test. For Equipent located in non-severe environments, the most severe condition that can challenge operation of the equignent is the seismic event; therefore, the seismic parameters are inse'rted' last. It should be pointed out that the abnormal temperature condition and the low sodium aerosol environment represent design requirements for which the equiprnent can be designed to prevent failures. Even though equignent located in non-severe environments will be designed to operate for the off normal temperature and aerosol environments, CRBRP requires that the equignent be qualified for these environments per Section 4.1 of WARD-D-0165.

At present, no qualification testing has been completed for equipoent located in non-severe or severe sodium aerosol environments.

Each of three Class IE Diesel Generators and the auxiliary equipnent for each diesel generator are located in a separate diesel generator room which will not be exposed to sodium aerosols. Each room is served by 100% recirculating cooling system and therefore the ingestion of sodium aerosol into the diesel room is excluded.

ne combustion air to the diesel engines will be filtered by high efficiency (HEPA) filters with a filtration efficiency higher than the 99.97%. It is expected that the trace amounts of aerosol passing through the HEPA filters will not affect the operation of the diesel engines, i

QCS270.5-2 Amend. 68 May 1982 r%r6am .

Page-8(82-0254)[8,22] - #28 Question OCS 270.6 (3.111 WARD-D-0165, Section 4.2.2, its 9, discusses failures during testing. In case of the failure during the test, if a redesign or replacment has been pursued as a solution, the complete assembly must be tested again to assure qualification. Discuss your ccanitment to this rquirement.

Response

WARD-D-0165 endorses IEEE 323-1974, Section 6.8, which contains specific instructions regarding modification to equipnent which fails during testing. -

Modifications involving a redesign or a replacment to the quipnent or to the equipnent specification should not be made after the start of the type test.

CRBRP requires a test failure evaluation on a case by case basis to determine whether or not a rqualification in whole or in part is required.

Modifications, with additional confirmation testing, are pursued as a solution to a test failure only if full justification is provided to document that the change has no bearing on the validity of the test.

OCS270.6-1 Amend. 68 May 1982 fir-(03B -

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~ Page-9'(82'-0254) (8,22] - #28 5

'l Ouestion_OCS 270.7-(3.111 WARD-D-0165, Section 4.2.2, page 5, third paragraph: revise IEEE 383-1972 to IEEE 382-1972.

Response

%e typographical error has been corrected and forwarded to the NRC as part of t

Rev. 6 to WARD-D-0165.

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i QCS270.7-1 Amend. 68 May 1982 L _ .QB-0350 _

Page-10(82-0254) [8,22] - #28 Question OCS 270.8 (3.111 WARD-D-0165, Page 4.11, Figure 4.3 and the Table on page 4-13 discuss the aging method similar to the 10 C rule. It is the NRC staff position that the 10 C rule is not an acceptable aging method unless justified by providing the verification based on Arrhenius methodology. Discuss how you comply with this requirement.

Response

he CRBRP equipnent qualification program is designed to conform to IEEE - 323-1974 as clarified by the forward issued by Nuclear Power Engineering Committee (NPEC) on July 24, 1975, as IEEE 325A-1975. This statement includes to " utilize known technology in any aging program".

CRBRP recognizes the limitations of aging techniques and the existence and development of various aging theories. CRBRP evaluates the aging methods to be utilized by the equignent vendor. It is not acceptable for the 10 C rule to be applied without documented assurance that this technique fulfills the objectives of aging. Further CRBRP anticipates that due to the empirical nature of the 10 C rule, use of the Arrhenius model may be the most suitable method. This will be evaluated on a case by case basis. The CRBRP aging program establishes in WARD-D-0165, Section 4.2.2.1 guidance to ensure that equipnent suppliers are raluired to address the aging objectives of the qualification program.

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QCS270.8-1 Amend. 68 May 1982

___83-@250 ,

Page-ll(82-0254) [8,22] - #28 Ouestion OCS 270.9 (3.111 WNu>-D-0165, Section 2.2 defines the mild (non-severe) environment. The definition used by the staff for the mild environment is defined as "an environment that would at no time be more severe then the environment that would occur during normal plant operation or during anticipated operational occurrences". Discuss your compliance with the staff's definition for the mild environment.

ResDonse -

We CRBRP non-severe environment does include the same environmental parameters that are included in the NRC definition of a mild environment.

This applies to the parameters that occur on both IER's and CRBRP, such as temperature, humidity and seismic. The values for those parameters that are included in mild (IER) and non-severe (CRBRP) environments are those that result from normal plant operation, anticipated operational occurrences, or safe shutdown and operating base earthquakes. For the CRBRP design, an additional parameter, sodium aerosols, may be present. Due to the design of CRBRP, specifically the environmentally separated cells into which the plant is divided, the aerosols that may be present as a result of an accident are classified as (1) those that are present in the cell in which the accident occurs, or (2) those that may be present in other cells as a result of a slmrt ingestion period prior to isolation being completed. The aerosols present in the cell in which an accident occurs are classified as severe environmental parameters. The aerosols present in cells other than the accident cell are classified as non-severe since Class IE equipnent located in these areas are not expected to experience an environment any more severe than the environment resulting during normal plant operation or during anticipated operational occurrences.

n e aerosols associated with the non-severg environment are specified for CRBRP as a concentration in air of 15 mg/m3 and a deposited surface concentration of 0.1 g/m 2, he environmental parameters associated with a non-severe environment can be accarmodated by the equipnent design. These non-severe environmental parameters are addressed in the equipnent design specifications. CRBRP further requires that the equipaent be qualified to these parameters. A specific discussion of the qualification procedures appears in Section 4.2.1 of WARI)-IF0165, Rev. 6.

OCS270.9-1 Amend. 68 May 1982

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