ML20045A675

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Intervenor San Luis Obispo Mothers for Peace Third Set of Supplementary Interrogatories & Requests for Production of Documents to PG&E Re Aging.* W/Certificate of Svc.Related Correspondence
ML20045A675
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 06/04/1993
From: Culver N
SAN LUIS OBISPO MOTHERS FOR PEACE
To:
PACIFIC GAS & ELECTRIC CO.
References
CON-#293-14030 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9306110188
Download: ML20045A675 (11)


Text

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f) 3O RELATED CORRESPONDENCE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

'93 JN -8 r? :17 In the matter of Pacific Gas and Electric Company Docket No. S0-27S-OLA-2 Diablo Canyon Nuclear Power Plant S0-323-OLA-2 Units 1 and 2 ASLBP No. 92-SSS-03-OLA-2 Focility Operating Licenses No. DPR-BO and DPR-82 June 9, 1993 Intarvenor San Luis Obispo Mothers for Peace Third Set of Supplemental Interrogatories and Requests for the Production of Documents to Pacific Gas and Electric Compong Re: Aging Pursuant to 10 CFR 2.790b, Intervenor Son Luis Obispo Mothers for Peace C"SLOMFP"] hereby propounds written interrogatories and requests for the production of documents to be answered by licensee Pacific Gas and Electric Company C"PG8E"] under cath or offirmation according to the instructions and definitions contained in Attachment A of SLONFP First Set of Written Interrogatories and Requests for the Production of Documents to PG&E CFebruary 16, 1593].

Respectfully Submitted, Noncy Culver, President San Luis Obispo Mothers for Peace P.O. Box 169 Pismo Beach, CA 93948 9306110188 930604 PDR ADOCK 05000275 e PDR O

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Interrogatories and Requests for the Production of Documents Re: Aging Note: PG&E has previously objected to all interrogatories relating to

" environmental qualification." However, SLONFP understands from the Atcmic Sofety and Licensing Board's decision on May 12, 1993 Cnot yet documented]

that the maintenance of environments for environmentally qualified '

equipment is a maintenance issue. SLDNFP, therefore, requests that all interrogatories requesting information on environmental qualification of equipment be answered.

L 1.

Answer interrogatories 1 through 9 below with respect to the following  !

important-to-sofety components located in a harsh environment: <

check volves ,

Limitorque volve operators cables with bonded Hypolon jockets i cables listed in Attachment 1 to Information Notice 93-33 CApril 28, 1993] 1 c3 Describe the methodCs], if any, used by PG&E to determine whether the octual operating environment is bounded by the conditions to which the ,

component was aged during environmental qualification testing, or which  ;

were assumed for purposes of environmental qualif ication. In addition,  ;

s please provide the results of such methodCs] as they have been applied to each component. '

b] Provide the equipment qualification files for these components.

Aging Due to Temperature

2. In NRC Information Notice No. 89-30 CMorch 15, 1989], the NRC clerted i licensees to " potential problems resulting from high temperature environments in creas that contoin safety-related equipment or electrical cables." Id, at 1. 2 The NRC noted that "It is important for-licensees to

________ 6 1 Information Notice 93-33, re: Potential Deficiency of Certain Class 1E Instrumentation and Control Cables, was served on the Licensing  :

Board and porties via Board Notification 93-11 (May 5, 1993].

2 A copy of NRC Information Notice No. 89-30 CNorch 15, 1989) is i ottoched to SLOMFP Second Set of Supplemental Interrogatories Re:

Cables CMoy 21, 1993)).

be owcre that there are crecs within the plant where the lacci temperature i

may exceed equipment qualifir. lon specifications even when the bulk temperature, os measured by a limited number of sensors, is indicating that '

it is lower than the qualification temperature." Jd2 at 3. SLONFP seeks to determine the methods, occuracy and situations under which PG&E measures local temperature to which important-to-sofety equipment is subjected r

c) Provide o description of the method for measuring the temperature inside containment and a description of the method for measuring the ,

temperature in other creas where important-to-sofety equipment is i

located. Into what zones,-if any, is the containment broken for purposes ,

t of temperature measurement? Please provide-Ci] the results of all such temperature measurements; Cli] the results of any comparisons between these temperature

measurements and environmental qualification specifications for important- l to-sofety equipment in each zone. l b) Provide copies of any documents generated in response to Temporary 1

Instruction 2515/98, "Information of High Temperature Inside i e

I Containment /Drywell in PWR ond BWR Plants: CJune 30, 1988]. [This document i I

is referenced in Information Notice 89-30 at page 1.]  !

I 4

c] Information Notice 89-30 states that: "It is expected that )

recipients will review the information [provided in the Information Notice]

i for opplicobility to their facilities and consider actions, os appropriate, to avoid similar problems." Describe your evoluotion of the coplicobility of this information Notice to Dichlo Congon Nuclear Power Plant C"DCNPP"]

and discuss any actions that have been token or considered to avoid similar problems. In addition, please provide copies of any documents that discuss your analysis, os well as any changes that have been made or l

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1

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contemploted. 3

3. In Information Notice No. 99-30, Supp. 1 CNovember 1, 1990] Cottcched],

the NRC describes instances in which elevated temperatures had adverse effects on operobility of emergency diesel generators and solid state protection system clarms. The Information Notice states that: "It is expected that recipients will review the information for applicobility to their Ecc111 ties and consider actions, os oppropriate, to avoid similar  ;

problems." In addition, please provide copies of any documents that discuss your analysis, os well as any changes that have been made or contemplated.

Aging Due to Vibration

9. SLOMFP seeks to determine the methods, occuracy and situations under which PG8E measures vibration to which important-to-sofety equipment is subjected. Provide o description of the method for measuring vibration inside containment and a description of the method for measuring vibration in other crecs where important-to-sofety equipment is located. Into what >

zones, if any, is the containment broken for purposes of vibration measurement? Please provide:

Ci] the results of all such vibration measurements; Cli) the results of any comparisons between these vibration measurements and environmental qualification specifications for important-  ;

to-sofety equipment in each zone.

~~~~~ '

3 SLOMFP ocknowledges receipt of Memorandum dated June 14, 1989 regarding NRC IE Notice 89-30 and Memorandum dated February 13, 1989 regarding NRC Information Notice 87-65.

i Aging Due to Humidity i S. SLOMFP seeks to determine the methods, occuracy and situctions under which PGSE measures humidity to which important-to-sofety equipment is  !

subjected. Provide o description of the method for measuring humidity inside containment and a description of the method for measuring humidity in other crecs where important-to-sofety equipment is located. Into what zones, if any, is the containment broken for purposes of humidity i measurement? Please nrovide:

[1] the results of all such humidity measurements; C11] the results of any comparisons between these humidity ,

measurements and environmental qualification specifications for important- ~

to-sofety equipment in each zone.

i Aging Due to Radiation Exposure S. SLOMFP seeks to determine the methods, occuracy and situations under which PG&E measures radiction exposure to which important-to-sofety equipment is subjected. Provide o description of the method for measuring radiction exposure inside containment and a description of the method for measuring radiction exposure in other crecs where important-to-  !

safety equipment is located, into wnot zones, if any, is the contoinment

)

broken for purposes of radiction exposure measurement? Please provide- J l

Ci] the results of oli such radiction exposure measurements; C113 the results of any comparisons between these radiction exposure measurements and environmental qualification specifications for important-to-sofety equipment in each zone.

Aging Due to Corrosion i

7.

SLCMFP seeks to determine the methods, occuracy and situations under i

l c _ _ _ _ _ _ _ _- - -- - - -

b which PGSE measures corrosion to which important-to-scraty aqutpmunt tw '

subjected.

Provide a description of the method for mecsuring corrosion t

inside containment and a description of the method for maamuring corrouton in other crecs where important-to-sofety equipment is located. Into what zones, if any, is the containment broken for purposes of corrosion measurement? Please provide:

Ci] the results of all such corrosion measurements; Cii] the results of any comparisons between these corrosion measurements and environmental qualification specifications for impcrtant-to-sofety equipment in each zone.

Aging Due to Submergence

8. SLOMFP seeks to determine the methods, occuracy and situations under ,

uhich PGSE measures submergence to which important-to-sofety equipment is ,

subjected. Provide o description of the method for measuring submergence inside containment cnd a description of the method for measuring 1

submergence in other crecs where important-to-sofety equipment is located. )

Into what zones, if any, is the containment broken for purposes of l

\

submergence measurement? Please provide:

E Ci] the results of all such submergence measurements; Cii) the results of any comparisons between these submergence measurements and environmental qualification specifications for'important-to-sofety equipment in each zone.

Aging Due to o Combination of Factors (such as a combinction of vibration and corrosion]

9. SLOMFP seeks to determine the methods, occuracy and situations under which PG&E measures a combinction of factors (such as vibration and corrosion] to which important-to-sofety equipment is subjected. Provide o i

description of the method for measuring a combination of factors inside containment and a description of the method for measuring a combination of factors in other creas where important-to-sofety equipment is located.

Into what zones, if any, is the containment broken for purposes of combination of factors measurement? Please provide:

Ei] the results of all such combination of factors measurements Cli) the results of any comparisons between these combination of factors measurements and environmental qualification specifications for important-to-sofety equipment in each zone.

Steam Generators

10. When DCNPP was first constructed, what was the expected qualified life

)

of the steam generator tubes which constitute port of the primary pressure boundary?

II. How has your maintenance program measured the environment of the tubes to see if they are within their quality environment?

lZ. What has been the experience with steam generator tube failures in terms of the mean time to degrade or fail?

13. As of this date, for each of the steam generators, what number of tube-out of the total have been plugged? Give the answer in number and percent Bf. How does the failure rote experienced to date on steam generator tubes compare to the estimated qualified life?

g UNITEDSTAk -

NUCLEAR REGULATORY (PMMISSION OFFICE OF NUCLEAR REAC1TTR REGULATION WASHINGTON, D.C.a 20555 5

Novemoer1,18l0 NRC INFORMATION NOTICE NO. 89-30, SUPPLEMENT 1: HIGH TEMPERATURE ENVIRONMENTS AT NUCLEAR POWER PLANTS Addressees:

All holders of operating licenses or construction permits for nuclear power i reactors.

Purpose:

This information notice supplement is being provided to present additional information regarding the effects of elevated room temperature on the operability of safety related equipment as discussed in NRC Information Notice 89-30, issued March 15, 1989. It is expected that recipients will review the information for applicability to their facilities and consider actions, as appropriate, to avoid sidlar problems. However, suggestions contained in this information notice do not constitute NRC requirements; therefore, no  :

specific action or written response is required.

Description of Circumstances:

Information Notice No. 89-30 described events where elevated temperatures and high humidity within the drywell or containment adversely impacted the operability of safety related ecuipment. This supplement describes events where high arbient temperatures in areas other than the containment or the drywell caused the failure or degracation of safety related equipment.

On June 25, 1990, the Omaha Public Power District (the licensee) conducted a full load test on the No.1 emergency diesel generator (EDG) at Fort Calhoun Unit 1. This test was conducted to establish a temperature profile for the EDG room. The test was terminated when the output from the generator became erratic as a result of the failure of a transistor in the static exciter circu itry.

The licensee's investigation revealed that the transistor had failed because of the effects of elevated temperatures in the static exciter / voltage regulator cabinet which was located in the EDG room. Temperatures in the cabinet had reached 140 degrees Fahrenheit (F) during the test. The transistor was replaced and the EDG was returned to operable status. The licensee airo discovered elevated temperatures in the static exciter / voltage regulator cabinet for the No. 2 EDG. In a recently completed engineering analysis, the licensee verified ,

that because of inadequate cabinet ventilation, a potential common mode failure of both EDGs exists. The analysis also concluded that this condition has likely existed since plant startup.

  • N B N O, Su;olement i November 1, 1990 rage 2 of 3 To reduce the potential for heat buildup in the cabinets, the cabinet doors were temporarily removed until a long term solution to the problem can be formulated.

The licensee's investigation of this event also revealed that elevated room tem-peratures significantly impact the coerating efficiency of the EDGs and could lead to accelerated degradation.

Discussion:

The Fort Calhoun Station has two General Motors EMD 20-645E4 diesel generator sets. The cooling system for each EDG consists of an engine radiator, an engine-driven fan, and a pump that circulates cooling water through the engine and radiator. Outside air is drawn into the EDG room by the fan, is blown across the radiator, and exits through the roof of the building through air ducts. Inlet air for the diesel turbocharger is drawn directly from the EDG room.

In June 1988 the licensee modified the hangers on the diesel exhaust headers.

These modifications required that the insulating material on the headers be removed. After removing the insulating material, the licensee was aware that ambient temperature would increase. Therefore, the licensee performed an analysis to support a design change that would allow the exhaust headers to remain uninsulated. The analysis concluded that bulk temperature in the EDG rooms would rise by only 9 degrees F and that this increase would not have an adverse effect on the operability of the EDGs. The analysis did not specifically address the effect of elevated room temperature on other equipment located in the room. -- .

When test runs were made during the sumer months of 1989, the licensee found that bulk room temperatures actually increased approximately 20 degrees F, or more thEn twice the increase predicted by the licensee's analysis. This ele-vated room temperature likely accelerated the degradation of the exciter com-ponent that failed. However, the potential for the temperature buildup in the unvented cabinet probably existed since the cabinets were installed.

The licensee also has determined that the 20 degree rise in ambient temperature resulted in an increase in jacket water temperature and turbocharger inlet air temperature. These temperature increases adversely affect engine operating efficiency. Depending on the amount of increase, elevated jacket water temperature and/or turbocharger inlet air temperature, combined with heavy loading, may lead to accelerated degradation of the engine. This degradation could result in engine failure .r prevent the engine from meeting its designed run time as assumed in the Final Safety Analysis Report. To reduce the poten-tial for engine degradation while operating during periods of high ambient temperatures, unit loading would have to be limited. Derating the EDG could result in the unit's dependable output capability being less than required for design basis accident loads.

Because of variations in the configurations of intake air systems, turbocharger inlet air may be preheated significantly. The temperature of the air entering the turbocharger may be much higher than air temperature elsewhere. Also, water-to-air heat exchangers are more sensitive to changes in ambient temperature i

i

IN 89-30, Supplemant'I Novemoer 1, 1990 Page 3 of 3 than are water-to-dater heat exchangers. However, an increase in service water temperature in water-to-water heat exchangers may also result in the derating of an EDG. The NRC is aware of other instances in which elevated ambient temp-eratures resulted in the failure or degradation of safety related components.

To avoid excessive cabinet temperatures and subsequent component failures, the licensee for the Washington Nuclear Project, Unit 2, has instituted admin-istrative procedures to remove the doors from the static exciter voltage regulator cabinet when the EDG room temperature exceeds 90 degrees F. The licensee performed an analysis which concluded that internal temperatures in the cabinets would exceed the long-term (greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) thermal rating of the cabinet components if the EDG room temperature were to exceed 90 degrees F.

Extended operation at or above this temperature would significantly increase the probability of a component failure.

On December 16, 1985, the failure of a fan in an engineered safety features (ESF) cabinet at Palo Verde Unit i resulted in the spurious actuation of several E5F signals. These signals initiated the automatic start of the Train A EDG, caused loads to be shed from the Train A vital bus, and initiated the operation of the ESF load sequencer. The load shed signal did not clear, prohibiting the automatic or manual sequencing of ESF electrical loads. The licensee installed a contro.1 room alarm that annunciates on cabinet exit air high temperature.

On June 4, 1984, at the McGuire Station, a total loss of control area ventilation resulted in temperature build-up in instrumentation cabinets. The elevated temperatures initiated several spurious solid state protection system alarms and resulted in the operators having to reduce output from both generating units.

This event is described in detail in IE Information Notice No. 85-89, " Potential Loss of Solid State Instrumentation Following Failure of Control Room Cooling."

On September 21, 1982, a similar event occurred at Davis-Besse Unit 1, and involved the failure of a 48-volt power supply in the Steam and Feedwater Rupture Control System (SFRCS). The failure of the power supply was attributed to heat buildup in the SFRCS cabinets. The licensee installed fans in the cabinets to ensure more effective cooling.

This information notice requires no specific action or written response. If you have any questions about the information in this notice, please contact one of the technical contacts listed below or the appropriate NRR project manager.

Mk b harles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Technical Contacts: C. Paulk, Region IV ,

(817) 860-8236 N. Fields, NRR  ;

(301) 492-1173

Attachment:

List of Recently Issued NRC Information Notices

Certificate of Service

'93 JZ -B P 2 C B I herebyfor Mothers certify Peace that copies Third of Supplemental Set of the foregoing Intervenor San Luis Obispo for thehave Aging Production of Documents been served upon theto following Pacific Gas and Electric Company Re: Interrogator or by FAX os indicated C*]. persons by U.S. muil, firmh c1 mum Office of Commission Appellote Administrative Judge Adjudication Charles Bechhoefer, Chairman U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Raguictory Commimuion Ucshington, DC 20555 Administrative Judge Jerry Kline Administrative Judge Atomic Safety and Licensing Board Frederick J. Shan U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Ecord Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Edward O'Neill Ann P. Hodgdon, Esq. Peter Arth, Jr.

Office of the General Counsel Trumon Burns U.S. Nuclear Regulatory Commission Robert Kinosion Washington, DC 20555 Peter G. Fairchild, Esq.

California Public Utilities Commission Joseph B. Knotts, Jr., Esq.* 505 Uon Ness Avenue Winston & Strown San Francisco, CA S9102 1900 L Street, N.W.

Washington, DC 20005 Adjudicatory File Secretcry of the Commission J.S. Nuclear Regulatory Commission Docketing and Service Branch

, Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Robert R. Wellington, Esq.

Diablo Congon Independent Safety Committee 857 Cass Street, Suite D Monterey, CA 93990 Christopher Warner, Esq.*

Richard Locke, Esq. i Pacific Gos and Electric Co.

77 Beale Street Son Francisco,. CA 99105

4 Jill 2cmEk

'T Dated June 4, 1993, Son Luis Obispo County, CA

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